The ratio of U.S. government debt to GDP has reached 100%, a milestone not seen since World War II. According to a new Government Accountability Office (GAO) report, the federal debt held by the public has equaled the nation's total economic output. Analysts warn that without immediate policy changes, debt will continue to outpace the…
Genesis and Legal Foundations of Pillar Two in the OECD/G20
Framework Pillar Two, the product of the OECD/G20 work on base erosion and profit shifting (BEPS 2.0), constitutes the most ambitious reform of international taxation since the OECD and UN model conventions. Its stated objective is to establish a minimum effective tax rate of 15%…
As of July 2, 2026, the |...| strategy started in May remains valid, with all four assets declining. Current returns for a |...|x short range from -185% to -297%:
- STXUSDT: -23.3% to -29.7% decline, ROI -233% to -297%; - LINKUSDT: -6.5% to -18.5% decline, ROI -65% to -185%; - AVAXUSDT: -25.8% to…
On the last day of June, gold traded at $4,023 per ounce. Oversea-Chinese Banking Corporation (OCBC), a major Southeast Asian bank, lowered its year-end gold forecast from $5,100 to $4,360, citing rising real yields, a stronger U.S. dollar, and a more hawkish Federal Reserve policy.
https://www.steelldy-indices.com
The bank also reduced its silver forecast by about…
The quantitative analysis reveals that Nike's Effective Tax Rate (ETR) dropped from 33.6% in Q4 FY2025 to 19.6% in Q4 FY2026, a statistically extreme anomaly of -14 percentage points. This exceeds the sector standard deviation of ~3%, yielding a Z-score of -4.67σ, indicating over 99.99% certainty that this is not a normal fluctuation.
https://www.steelldy-indices.com
Compared…
On June 30, 2026, @Nike (NKE) reported Q4 FY2026 results that appeared to show a spectacular rebound: Net Income of $1.1 billion, up 407% and far above the consensus of $0.13. However, this performance was not due to operational improvement but to an accounting artifact: a $986 million customs duty refund expected from a U.S.…
The Real Asset Shifting (RAS) module (www.steelldy-indices.com) focuses on tangible assets, notably cross-border real estate. However, intangible assets (patents, trademarks, software, know-how, databases, client lists) are historically the main channel for profit shifting in multinational groups. Unlike tangible assets, intangibles do not significantly benefit from the Substance-based Income Exclusion (SBIE), are highly sensitive to transfer…
L’administration fiscale française a engagé une mutation systémique de son contrôle fiscal via le projet PILAT (Pilotage et Analyse du Contrôle) et l’outil GALAXIE, qui constituent une infrastructure algorithmique de ciblage massif. Ces outils transforment l’ensemble des données fiscales, patrimoniales et relationnelles en un score de risque attribué à chaque contribuable. Le projet PILAT, lancé…
The Substance-based Income Exclusion (SBIE) is a carve-out mechanism under Pillar Two (GloBE) that excludes part of a jurisdiction's GloBE Income before calculating top-up tax, recognizing real economic substance. Its formula for 2022 rules with 2024-2026 guidance is 5% of eligible payroll plus 5% of tangible assets' carrying value.
Payroll includes eligible employee expenses,…
Société Générale projects a more moderate pace of gold purchases by central banks in the future. While central bank demand has been a key driver of gold's multi-year rise to an all-time high of $5,600, and a recent World Gold Council survey indicates continued official sector buying, one bank adopts a cautious stance, warning that…
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