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Yearly Archives: 2026

HomeYearly Archives: 2026
Chroniques juridiques

Stochastic Modeling of the Impact of Pillar Two (OECD) on Tax Engineering and the Valuation of Tokenized Carbon Investments (TCC): Correlation Analysis Between STEELLDY’s CCQI Index and the Risk-Adjusted Tax Performance of TCCs in French Jurisdiction

The impact of the Pillar Two international tax regime (OECD) on the valuation and structuring of tokenized carbon credit (TCC) investments, particularly in France. (A) Structural effect of Pillar Two on the taxation of TCCs ¤ Pillar Two imposes a minimum effective rate of 15% on the profits of multinational corporations, neutralizing tax optimization…
mai 10, 20260Comments

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Chroniques juridiques

Modeling of « TEnergies' » profit shifting anomalies via the Geneva hub through the lens of GloBE rules (Pillar Two)

Multi-model analysis of regulatory and OSINT data confirms with 99.4% confidence that TEnergies utilizes a complex tax optimization structure centered on its Geneva trading subsidiary. This structure uses the "Rest of the World" category in tax reports as a proxy for low-tax jurisdictions, primarily Switzerland. The implementation of the OECD Pillar Two GloBE rules,…
mai 9, 20260Comments

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DécarbonisationDécarbonisation Transition énergétiqueTransition énergétique

Pillar Two’s Silent Killer: How GloBE Rules Decimate Tax Benefits for Tokenized Carbon Credits

The widespread implementation of OECD Pillar Two (GloBE rules) starting in fiscal year 2024-2025 fundamentally alters the economics of tokenized carbon credit investment. This analysis, based on quantitative modeling and international tax doctrine, demonstrates three key effects: Pillar Two erodes the tax value of tokenized carbon credits by neutralizing non-refundable tax credits and ESG incentives…
mai 9, 20260Comments

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Analyse de marchéAnalyse de marché

Ray Dalio Ups Gold Allocation Forecast Amid Dollar Devaluation and Global Crisis Fears

Gold Is Moving Back to the Center of Finance By Peter Reagan Gold is reasserting itself in finance, moving from an "alternative asset" category to a core holding, driven by recent economic instability. Historically, institutional investors focused mainly on corporate profits and debt, viewing gold skeptically. However, the pandemic-era lockdowns, subsequent inflation, and the significant…
mai 6, 20260Comments

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Cryptos

Bitcoin : Expansion Post-Stabilisation & Breakeven Battlefield

The Glassnode "Expansion, Breakdown, Stabilization" framework identifies a mature stabilization phase with volatility-adjusted support built around ~$74,000 and confluent resistance at $80,000–$83,000. This $78K–$83K zone constitutes the "Breakeven Battlefield" where the following overlap: (i) the STH Cost Basis at $78,700 (v5.0), (ii) the True Market Mean Price at ~$81,500 (v3.0), and (iii) the ETF Cost…
mai 5, 20260Comments

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Analyse de marchéAnalyse de marché

The convergence of physical, behavioral, and microstructural signals confirms that Europe, and particularly France, has entered a regime of asynchronous systemic energy shortage

The convergence of physical, behavioral, and microstructural signals confirms that Europe, and particularly France, has entered a regime of asynchronous systemic energy shortage. The three pillars of the breakdown: (a) Physical Pillar. The Strait of Hormuz has been practically blocked since February 28, 2026: more than 20% of global oil traffic and 25% of…
mai 4, 20260Comments

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En chiffresEn chiffres

Closure of the straits (Malacca/Hormuz). Systemic famine scenario 2026-2028 : in the French context.

Analysis of signals from Steelldy Engine G (maritime AIS), Steelldy Engine F (fertilizer blockages), Steelldy Engine M (semantic panic), and Steelldy Engine O (strait closure probabilities) shows exceptional statistical convergence. Michael Yon's analysis (Feb-Apr 2026) regarding prolonged Strait of Hormuz closure and imminent Malacca Strait threats is now a 78% market reality (95% CI: 72–84%),…
mai 2, 20260Comments

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