Monday, June 30, 2025

KIKI_Time

 Wrapping up June which is still Pride month. Found this classic tune of

the genre.

Should point out that - in French -  KIKI is baby talk for cookie ( un bicuit).

Whatever...

                                                 


                                                         *     *     *

And then there are those...  who dance:


Sunday, June 29, 2025

Profits

 How muxh in profits did Google and Facebook declare last year?

                                                                       




Here’s how Google and Facebook stack up against two other tech titans—Apple and Amazon—in terms of 2024 profits:

                                                                          

What does this mean for the future of the tech industry?

The massive profits posted by Google, Meta, Apple, and Amazon in 2024 signal more than just financial success—they’re a loud bellwether for where the tech industry is headed. Here’s what it all points to:

๐Ÿš€ 1. AI Is the New Gold Rush
These companies are doubling down on AI infrastructure and products, from search and ads to cloud and hardware.
Expect more agentic AI—autonomous systems that don’t just respond but act independently to complete tasks.
AI is becoming a core utility, like electricity or the internet.

๐ŸŒ 2. Platform Power Is Consolidating
With profits this high, Big Tech is cementing its dominance. Smaller players may struggle to compete unless they innovate fast or get acquired.
These giants are also expanding into adjacent industries—healthcare, finance, education—blurring traditional sector lines.

๐Ÿ“‰ 3. Efficiency Over Expansion
Much of the profit growth came from cost-cutting and automation, not just revenue spikes.
This signals a shift from “grow at all costs” to sustainable, leaner operations—especially in uncertain economic climates.

๐Ÿ” 4. Regulation Is Inevitable
Governments are watching. With this level of influence and cash flow, antitrust scrutiny and AI regulation are heating up globally.
Companies will need to balance innovation with ethical and legal guardrails.

๐ŸŒ 5. Global Tech Ecosystems Will Evolve
Emerging markets may see more investment as Big Tech looks for new users and talent.
At the same time, data sovereignty and digital borders are becoming more pronounced, leading to regional tech ecosystems.

In short: the future of tech is smarter, more automated, and more powerful—but also more scrutinized. Want to dive into how this might affect jobs, startups, or even your own digital lif

What are the global implications of these trends?

The global implications of Big Tech’s explosive growth and emerging trends are vast—and they ripple far beyond Silicon Valley. Here's how the world is being reshaped:

๐ŸŒ 1. Digital Power Shifts
Countries with strong tech sectors (like the U.S., China, and India) are gaining geopolitical influence.
Nations without robust digital infrastructure risk falling behind, creating a digital divide that mirrors economic inequality.

๐Ÿง  2. AI Arms Race
As AI becomes a strategic asset, governments are racing to develop or regulate it.
This could lead to tech nationalism, where countries prioritize domestic AI ecosystems—potentially fragmenting global collaboration.

๐Ÿ’ผ 3. Workforce Transformation
Automation and AI are reshaping jobs worldwide—some roles vanish, others emerge.
Countries with strong education and reskilling programs will thrive; others may face unemployment spikes and social unrest.

๐Ÿ›ก️ 4. Cybersecurity & Data Sovereignty
With more data crossing borders, cyber threats and espionage are escalating.
Nations are enforcing data localization laws, demanding that companies store data within national borders—reshaping cloud and internet architecture.

๐Ÿ“Š 5. Global Economic Realignment
Big Tech’s dominance is shifting capital flows. Startups and smaller economies may struggle to compete unless they specialize or form alliances.
Expect more cross-border M&A, tech diplomacy, and digital trade agreements.

๐ŸŒฑ 6. Environmental Impact
AI and cloud computing require massive energy. The push for sustainable tech infrastructure (like nuclear-powered data centers) is becoming a global priority.

In essence, tech trends are no longer just about gadgets or apps—they’re redefining global power, labor, and even the environment. Want to zoom in on how this might affect a specific region or industry?


Can you explain more about the AI arms race?

Absolutely—this is one of the most defining global dynamics of our time. The AI arms race refers to the intense competition among nations and corporations to develop and dominate artificial intelligence technologies. But unlike traditional arms races, this one isn’t just about military might—it’s about economic power, geopolitical influence, and control over the future of innovation.

๐ŸŒ Who’s in the race?

United States: Home to OpenAI, Google, Microsoft, and NVIDIA—leaders in large language models, AI chips, and cloud infrastructure.
China: Backed by state-driven initiatives, companies like Baidu and DeepSeek are rapidly advancing AI under national strategic goals.
European Union: Less focused on raw power, more on regulation and ethics, with the AI Act aiming to set global standards.
Others: Countries like the UK, India, Israel, and Russia are also investing heavily in AI for defense, healthcare, and economic growth.

⚔️ What’s at stake?

Military dominance: AI is transforming warfare—from autonomous drones to real-time battlefield intelligence. Ukraine, for example, has used AI-powered drones and targeting systems to great effect in its defense against Russia.
Economic supremacy: Nations that lead in AI will likely control the next wave of productivity, innovation, and job creation.
Information control: AI tools can shape public opinion, detect threats, or spread disinformation—making them powerful in both diplomacy and propaganda.

๐Ÿงญ Risks and ethical dilemmas

Autonomous weapons: Who’s accountable if an AI drone makes a lethal mistake?
Global inequality: Countries without access to AI infrastructure risk falling behind.
Regulatory gaps: Without global coordination, we could see a fragmented, unstable AI landscape.

๐Ÿ”ฎ What’s next?

Expect more national AI strategies, cross-border alliances, and techno-diplomacy.
The race could lead to breakthroughs in medicine, climate modeling, and education—but also to new forms of surveillance and control if left unchecked.

It’s a high-stakes sprint with no finish line—just a constantly shifting frontier. Want to explore how this might affect your country, your job, or even your personal data?

How do China's and the US's AI strategies compare?

The AI strategies of China and the United States reflect two very different philosophies—one centralized and infrastructure-heavy, the other decentralized and innovation-driven. Let’s break it down:

๐Ÿ‡จ๐Ÿ‡ณ China’s AI Strategy: State-Led and Infrastructure-First
Core Features:
Top-down planning: Anchored by the 2017 Next Generation AI Development Plan, aiming for global AI leadership by 2030.
Massive public investment: In 2025 alone, China is projected to spend up to $98 billion on AI, with $56 billion from government sources.
Infrastructure focus: Prioritizes building data centers, green energy grids, and compute clusters—especially in inland provinces.
Open-source pivot: Companies like Baidu and DeepSeek are releasing powerful models (e.g., ERNIE) as open source to undercut Western pricing and boost adoption4.
Global outreach: Through the Digital Silk Road, China exports AI infrastructure and governance models to developing nations.
Strategic Goals:
Achieve technological self-reliance, especially in semiconductors.
Embed Chinese AI standards globally.
Use AI to modernize sectors like healthcare, manufacturing, and surveillance.

๐Ÿ‡บ๐Ÿ‡ธ U.S. AI Strategy: Innovation-Led and Ethics-Focused
Core Features:
Public-private synergy: Leverages tech giants (OpenAI, Google, Microsoft) and academia, with billions in R&D funding.
Regulatory leadership: Introduced the AI Bill of Rights, NIST Risk Management Framework, and Executive Orders on AI safety.
Alliances & diplomacy: Leads global initiatives like the Hiroshima AI Process and Partnership for Global Inclusivity on AI.
Defense integration: The Pentagon’s AI strategy emphasizes battlefield decision advantage and responsible military AI use.
Compute democratization: Launching the National AI Research Resource to give researchers access to high-performance computing.
Strategic goals:
Maintain global AI leadership through innovation and ethical standards.
Counter authoritarian AI models.
Promote safe, secure, and rights-respecting AI globally.

Key Contrasts:

                                                                                    

In essence, China is building a fortress of compute and influence, while the U.S. is trying to lead with values, alliances, and innovation. Both are racing toward the same finish line—but on very different tracks.

Would you like to explore how these strategies affect global AI governance or the open-source movement?








About_Venice

                                                                                



Copilot:

Why is Venice called La Serenissima; what does this mean?

๐Ÿ‡ฎ๐Ÿ‡น "La Serenissima" means "The Most Serene"—and it was the official title of the Republic of Venice for centuries. The full name was La Serenissima Repubblica di Venezia, or The Most Serene Republic of Venice. Here's why that nickname stuck:

๐Ÿ•Š️ A Title of Prestige and Power

“Serenissima” is the superlative form of sereno, which means serene or calm in Italian.

It was a diplomatic and honorific title, symbolizing Venice’s claimed political stability, wise governance, and independence—especially during the chaos of medieval Europe.

⚖️ A Republic Like No Other

Venice was a sovereign republic for over a thousand years (697–1797), governed by an elected Doge and a powerful aristocratic council.

Unlike many other states ruled by monarchs or embroiled in frequent wars, Venice projected an image of calm order—even though it was deeply involved in politics, trade, and sometimes ruthless ambition.

๐ŸŒŠ A Calm Oasis on the Water

Built on a lagoon, Venice embodied a kind of mystical serenity—floating between sea and sky, beautiful and seemingly untouched by time.

The title also helped Venice stand apart from rival maritime powers like Genoa, Pisa, and later, the Ottoman Empire.

Venetians leaned into this branding: even coins, official documents, and ships bore symbols of “La Serenissima.” Pretty clever for a city that ran a trade empire stretching from Crete to Cyprus to Constantinople, all while managing to look effortlessly graceful.

Would you like a glimpse into how Venice kept that serenity while orchestrating power plays across Europe and the Mediterranean? Their secret diplomacy is the stuff of legend.


Tell me!!

๐Ÿ•ต️‍♂️ Venice’s famous serenity masked a world-class spy network. Here's how La Serenissima maintained control with surprising subtlety:

๐Ÿ—️ The Council of Ten: Venice’s Secret Keepers

This ultra-powerful body, created in 1310, handled state security, espionage, and internal surveillance.

It operated mostly in complete secrecy, answering only to the Doge but often wielding far more influence than him.

๐Ÿ“œ The Bocche di Leone (“Mouths of the Lion”)

These were public mailboxes with lion heads where citizens could anonymously denounce others for crimes or suspicious behavior—anything from tax evasion to treason.

The Council of Ten evaluated these tips and could dispatch secret agents without trial or fanfare.

๐Ÿ•ถ️ Professional Spies and Double Agents

Venetian merchants abroad often served as informal intelligence officers, sending back reports from Ottoman ports or Habsburg courts.

The Republic also employed multilingual spies, master forgers, and even defectors from rival states to stay one step ahead.

๐Ÿ” Control Through Silence and Sophistication

Venice banned many public discussions of politics. Gossip in a piazza could land you in prison—or worse.

Dissent was rare because the penalty for betrayal could be exile, torture, or death—sometimes carried out behind the marble walls of the Doge’s Palace without a trace.

๐Ÿ›ถ Through shrewd diplomacy, trade leverage, and ruthlessly efficient intelligence, Venice kept its empire remarkably stable—serene in appearance, but fiercely guarded in practice.

Would you like a peek inside the secret torture chambers or prisons beneath the Doge’s Palace? The Bridge of Sighs wasn’t just poetic—it led straight to the cells.


What is the famous Church and Plaza of Venice?

The most iconic duo in Venice is undoubtedly St. Mark’s Basilica and Piazza San Marco—they’re the heart and soul of the city.

⛪ St. Mark’s Basilica (Basilica di San Marco)

Known as the “Church of Gold”, it’s Venice’s most famous church, dazzling with golden mosaics, Byzantine domes, and treasures brought back from the East.

Originally built in the 9th century to house the relics of St. Mark the Evangelist, which were smuggled from Alexandria.

Inside, you’ll find the Pala d’Oro, a breathtaking golden altarpiece encrusted with gems, and over 8,000 square meters of mosaics.

The basilica’s architecture is a blend of Byzantine, Gothic, and Islamic influences, reflecting Venice’s role as a crossroads of cultures.


๐Ÿ›️ Piazza San Marco (St. Mark’s Square)

Napoleon once called it the “drawing room of Europe”—and it’s easy to see why.

Surrounded by historic buildings like the Doge’s Palace, the Campanile (bell tower), and the Procuratie, it’s the city’s grandest open space.

It’s where Venetians gathered for festivals, announcements, and even executions—though today it’s more about espresso and selfies.

During high tide (acqua alta), the square can flood, creating surreal reflections of the basilica and sky.

Would you like a virtual stroll through the square or a peek inside the basilica’s glittering interior? I can guide you through the highlights like a local.


These are on the island part of the city...

Exactly! ๐ŸŒŠ St. Mark’s Basilica and Piazza San Marco are both located on the main island cluster of Venice—right in the heart of the historic city, nestled between winding canals and elegant bridges.

Venice itself is built on a group of 118 small islands linked by over 400 bridges, and the city’s “main island” refers to the densely packed historic center. That’s where you’ll find:

๐Ÿ›️ St. Mark’s Square: the city’s ceremonial core

⛪ St. Mark’s Basilica and ๐Ÿฐ the Doge’s Palace: side by side, forming an iconic duo

๐Ÿ›Ž️ The Campanile (bell tower): a 99-meter-high perch with panoramic views of the lagoon

It’s all surrounded by the Grand Canal, shaped like a backward “S,” which divides the historic center into districts called sestieri.

Want to explore some of the quieter islands next? Murano (glass!), Burano (lace and rainbow houses!), or Torcello (Venice’s hauntingly ancient sibling) could be lovely detours.


Is St Marc's currently open to the public?

Yes! ⛪ St. Mark’s Basilica is currently open to the public, with the following visiting hours:

Monday to Saturday: 9:30 AM – 5:15 PM (last admission at 4:45 PM)

Sundays and Holy Days: 2:00 PM – 5:15 PM

You can also attend Mass or prayer services earlier in the day—entry for worship is free via the Porta dei Fiori on the north side.

๐ŸŽŸ️ Tickets are required for general sightseeing, and there are optional add-ons like the Pala d’Oro (a golden altarpiece) and the Museum – Loggia dei Cavalli. The Bell Tower is open daily until 9:15 PM, weather permitting.

Let me know if you’d like help booking tickets or planning the best time to visit to avoid the crowds. Venice rewards the early risers!


What's this about the plaza can flood. Surely one doe not want water in the Church!!

You're absolutely right—water in a 1,000-year-old basilica is every conservator’s nightmare. But Venice, being built on a lagoon, has always danced a delicate waltz with the tides. The phenomenon is called acqua alta (high water), and Piazza San Marco is the lowest point in the city, making it the first to flood when tides rise.

๐ŸŒŠ Why It Floods

The square begins to flood when tides reach just 60 cm above sea level—which happens around 250 times a year.

At 80–90 cm, large parts of the piazza are submerged.

At 100 cm, nearly the entire square—including the narthex of St. Mark’s Basilica—can be underwater.

๐Ÿ›ก️ How They’re Protecting It

Glass barriers were installed around the basilica in 2023 to block water from entering the church during moderate floods.

These barriers are temporary until the MOSE system—a massive underwater gate project—is fully operational (expected by the end of 2025). MOSE is designed to block high tides from entering the Venetian Lagoon altogether.

Inside the basilica, drainage systems and restoration efforts are ongoing to combat saltwater damage, which can age the structure “20 years in a day” during severe floods.

So yes, Venetians definitely don’t want water in the church—but they’ve become masters of managing it. Want to hear how the MOSE system works? It’s like something out of a sci-fi novel.


So the flooding is a relatively recent phenomenon...

Not quite—acqua alta has been part of Venetian life for centuries—but the frequency and severity of flooding have dramatically increased in recent decades.

๐ŸŒŠ A Long History, But a Modern Crisis

Venice has always experienced seasonal high tides, especially in autumn and winter, due to its lagoon setting and the Adriatic Sea’s tidal patterns.

However, the 1966 flood was a turning point: water levels reached a record 194 cm, submerging 80% of the city and causing catastrophic damage to art, homes, and infrastructure.

Since then, climate change, rising sea levels, and land subsidence have made flooding more frequent and intense. In fact, Venice now floods dozens of times a year, with some years seeing over 60 events.

๐Ÿ“ˆ What’s Changed?

Sea level rise is accelerating, and Venice is also sinking—about 1–2 mm per year due to natural and human-induced factors.

Storm surges and extreme weather events are more common, pushing water into the lagoon faster than the city can drain it.

๐Ÿ›ก️ The Response

The MOSE barrier system, a series of mobile gates at the lagoon’s inlets, is being deployed more frequently to protect the city. It’s a massive engineering feat, but experts warn it may not be enough by the end of the century under high-emission scenarios.

So while flooding isn’t new, the scale and urgency of the threat are very much modern. Venice is still breathtaking—but it’s also on the front lines of climate change. Want to see how the MOSE system works or what future projections look like? It’s both fascinating and sobering.


Is the Lagoon now completely given over to Tourism, or does it still function as a port?

Not at all—while tourism is undeniably the dominant force in Venice today, the Venetian Lagoon still functions as a working port and plays a vital role in regional commerce and transportation.

⚓ A Dual Identity: Tourism & Trade

The Port of Venice remains one of the largest and busiest ports in the Mediterranean, handling both passenger cruises and commercial freight.

It’s part of the Veneto Port System, which includes nearby Chioggia, and serves as a gateway for goods moving between Southern Europe and Central Europe.

Over 1,200 companies operate within the port system, supporting industries from steel to energy to logistics.

๐Ÿšข What Still Moves Through the Lagoon?

Containers, bulk cargo, steel, chemicals, and even oversized industrial equipment are regularly shipped through Porto Marghera, the industrial zone on the mainland side of the lagoon.

The port also maintains ferry and cruise connections to destinations like Greece, Croatia, and Egypt.

๐ŸŒฑ A Glimpse into the Future

Venice is investing in a green transition, turning parts of Porto Marghera into a clean energy hub with hydrogen and alternative fuels.

The lagoon is also home to fish farming and limited traditional fishing, though these are increasingly overshadowed by tourism.

So while gondolas and Aperol spritzes may dominate the postcards, Venice’s lagoon is still very much a living, working waterway—a place where cargo ships and cruise liners share space with vaporettos and fishing boats.

Curious about how Venice balances this industrial activity with preserving its fragile ecosystem? It’s a tightrope walk worth exploring.

Messy

Taxation mondiale des multinationales : Trump impose au reste du monde l’exemption des entreprises amรฉricaines

Face ร  la menace de guerre fiscale du gouvernement amรฉricain, qui envisageait de surtaxer les entreprises รฉtrangรจres aux Etats-Unis, les pays du G7 ont acceptรฉ de vider de sa substance une grande partie de l’accord d’impรดt minimal mondial de 15 %.
Publiรฉ aujourd’hui ร  06h44, modifiรฉ ร  08h27 
Temps deLecture 4 min.
Article rรฉservรฉ aux abonnรฉs
Une fois encore, la menace a fonctionnรฉ. En brandissant ces derniรจres semaines la possibilitรฉ d’appliquer un nouvel impรดt aux entreprises รฉtrangรจres, surnommรฉ « taxe de la vengeance », les Etats-Unis ont obtenu un recul majeur des autres pays du G7 sur un sujet fiscal qui irritait Donald Trump depuis son retour ร  la Maison Blanche : celui de la taxation des multinationales, et plus prรฉcisรฉment de l’impรดt minimal mondial sur les sociรฉtรฉs de 15 % dont le principe avait รฉtรฉ adoptรฉ en 2021 par 140 pays, sous l’รฉgide de l’Organisation de coopรฉration et de dรฉveloppement รฉconomiques (OCDE). Dรฉjร  entrรฉ en vigueur en 2024 dans un bon nombre d’Etats, dont ceux de l’Union europรฉenne mais aussi au Royaume-Uni, au Canada et au Japon, cet impรดt constituait un premier pas dans la lutte contre la concurrence fiscale dรฉloyale entre Etats.
Dรฉsireux de partager cette victoire amรฉricaine, Scott Bessent, le secrรฉtaire amรฉricain au Trรฉsor, l’a annoncรฉ dรจs jeudi 26 juin au soir sur le rรฉseau social X. « Aprรจs des mois de dialogue productif avec les autres pays de l’accord fiscal international de l’OCDE, nous allons annoncer une dรฉclaration conjointe avec les pays du G7, qui dรฉfendra les intรฉrรชts amรฉricains, a-t-il รฉcrit. (…) Le pilier 2 de l’OCDE [c’est-ร -dire la taxation minimale mondiale de 15 %] ne s’appliquera pas aux entreprises amรฉricaines. » L’information a รฉtรฉ confirmรฉe, vendredi 27 juin, au Monde par Bercy et par l’OCDE, alors que le G7 a finalisรฉ un projet de communiquรฉ que Le Monde a pu consulter.
« Le reste du G7 [France, Royaume-Uni, Allemagne, Italie, Canada, Japon] a capitulรฉ », estime Gary Clyde Hufbauer, du Peterson Institute for International Economics, un groupe de rรฉflexion amรฉricain. « La loi du plus fort a fonctionnรฉ. C’est un passe-droit accordรฉ aux Etats-Unis, mรชme si n’รฉtant pas un paradis fiscal, ils n’รฉtaient pas la cible de cette rรฉforme fiscale », regrette Pascal Saint-Amans, qui fut le nรฉgociateur de la rรฉforme fiscale pour l’OCDE.

Menace sur les entreprises รฉtrangรจres

L’accord de l’OCDE en 2021 constituait une avancรฉe majeure aprรจs de longues annรฉes de discussions tendues. La principale difficultรฉ avait รฉtรฉ d’y inclure les Etats-Unis, premiรจre puissance รฉconomique mondiale, dont les multinationales pratiquent couramment des mesures d’optimisation fiscale. A reculons, l’administration de Joe Biden avait fini par l’accepter. Depuis, la mise en ล“uvre de l’accord รฉtait lente. Mais si des nรฉgociations sont toujours en cours sur un grand nombre de sujets, le second pilier, celui sur la taxation minimale, commenรงait ร  entrer progressivement en vigueur, รฉtant dรฉsormais dรฉployรฉ dans une soixantaine de pays.
Lire aussi | Article rรฉservรฉ ร  nos abonnรฉs Donald Trump torpille l’impรดt minimum mondial sur les multinationales
Le problรจme est que les rรฉpublicains s’y sont toujours vivement opposรฉs. Dรจs le 20 janvier, le jour de son investiture, Donald Trump a signรฉ un mรฉmorandum annonรงant que « l’accord fiscal mondial [de l’OCDE] ne s’applique pas aux Etats-Unis ». Depuis, des discussions se sont multipliรฉes pour trouver un compromis, comme en tรฉmoigne l’รฉchange sur le sujet entre le ministre de l’รฉconomie, Eric Lombard, et M. Bessent, lors d’un G7 au Canada, en mai.
Mais ces discussions ont dรฉbouchรฉ sur un durcissement de la position amรฉricaine. Dans le One Big Beautiful Bill Act (littรฉralement : « un grand et beau projet de loi »), Washington a ajoutรฉ une modification de la section 899 du code fiscal, laquelle, dans la version votรฉe par la Chambre des reprรฉsentants, permettait d’instaurer un impรดt supplรฉmentaire de 20 % sur les groupes รฉtrangers venant de pays appliquant une fiscalitรฉ « injuste » ร  l’รฉgard des entreprises amรฉricaines. Des pays comme la France, le Royaume-Uni et le Canada, qui ont mis en place des impรดts sur les entreprises numรฉriques, รฉtaient particuliรจrement visรฉs.

« Pousser les autres pays ร  nรฉgocier »

Un vent de panique s’est alors levรฉ dans les milieux financiers, qui craignaient que ces surtaxes touchent aussi les placements boursiers ou les obligations du Trรฉsor amรฉricain. « Nos clients nous posent รฉnormรฉment de questions sur le sujet », soulignait mercredi Jean-Denis Bachot, le directeur gรฉnรฉral pour la France de Fidelity International, une sociรฉtรฉ de gestion amรฉricaine. Le retrait de cette modification fiscale leur a redonnรฉ le sourire.
« Cette section 899 รฉtait une menace, pour pousser les autres pays ร  nรฉgocier, estime George Gans, associรฉ au cabinet de conseil KPMG. Mais les Etats-Unis espรฉraient ne pas la mettre en place. Cela a marchรฉ plus vite que je ne le pensais. »
Si cet accord fait autant les affaires des Etats-Unis, pourquoi le reste du G7 l’a-t-il acceptรฉ ? « La section 899 aurait pรฉnalisรฉ les entreprises franรงaises [puisqu’elles risquaient de se faire surtaxer] », fait-on valoir ร  Bercy, oรน l’on ne cache pas un sentiment de soulagementUne telle surtaxe amรฉricaine aurait รฉgalement amputรฉ les bรฉnรฉfices rapatriรฉs en France et, par ricochet, les recettes fiscales de la France. « C’est une victoire pour les entreprises amรฉricaines, mais surtout pour les entreprises europรฉennes », estime mรชme Rosanna Burcheri, spรฉcialiste du marchรฉ actions amรฉricain ร  Fidelity International.

« Accord zombie »

Pas si sรปr, rรฉplique une source proche des nรฉgociations : car, avec ce compromis en faveur de Washington, le reste du G7 pรฉnalise ses propres entreprises, qui restent pour leur part soumises ร  l’impรดt minimal mondial.
Enfin, la crainte des six autres pays du G7 de voir les Etats-Unis claquer la porte de l’OCDE sur les questions fiscales, comme ils l’ont fait pour l’Organisation mondiale de la santรฉ ou l’accord de Paris sur le climat, explique aussi leur volontรฉ d’accepter un tel accord.
Avec ce compromis, les nรฉgociations au sein de l’OCDE restent officiellement en cours. Et rien n’empรชche le reste du monde de continuer ร  appliquer cette taxe : « La France peut continuer ร  imposer cette fiscalitรฉ minimale sur L’Orรฉal ou l’Australie sur Rio Tinto [un groupe minier australien] », suggรจre une source proche du dossier. « Je pense que les autres pays du G7 vont maintenir l’accord en vie entre eux en espรฉrant qu’ร  l’avenir un futur prรฉsident des Etats-Unis y revienne », estime M. Clyde Hufbauer, du Peterson Institute for International Economics. Un optimisme que ne partage pas Markus Meinzer, directeur de l’association Tax Justice Network, pour qui l’accord de l’OCDE est dรฉsormais un « accord zombie », dont l’acte de mort officiel vient d’รชtre signรฉ.
Par ailleurs, Bercy insiste sur le fait que « l’impรดt national complรฉmentaire » reste en place. Celui-ci, adoptรฉ en 2024 et qui sera payรฉ pour la premiรจre fois l’annรฉe prochaine, permet d’imposer une multinationale ร  15 % au minimum sur son activitรฉ en France. Mais il est restreint ร  l’activitรฉ franรงaise et ne s’รฉtendra plus ร  l’activitรฉ internationale, comme le prรฉvoyait l’accord de l’OCDE.
Au-delร , l’exemption accordรฉe aux multinationales amรฉricaines est un symptรดme de plus de la fragmentation mondiale de l’รฉconomie, selon M. Clyde Hufbauer : « La dรฉmondialisation s’est pour l’instant concentrรฉe sur le commerce. Mais la fiscalitรฉ est le prochain grand dossier. »

Read this somewhat odd report, yesterday; and had a conversation with Meta Ai
about it all. There seem to be two ways in which this can play out. Below:

Meta AI:

Explain to me the OECD's proposal for a 15% minimal tax on Corporations. Who calculates and receives this tax??

The OECD's proposal for a 15% minimum tax on corporations, also known as Pillar Two, aims to ensure large multinational enterprises (MNEs) pay a minimum effective tax rate of 15% on their profits. This agreement, signed by over 140 countries, targets MNEs with earnings above €750 million ($812 million). Here's how it works ¹:

Calculating the Tax: The tax is calculated based on the MNE's effective tax rate (ETR) in each jurisdiction where they operate. If the ETR falls below 15%, other countries can impose a top-up tax to bring the total tax rate up to the minimum level.

Receiving the Tax: Each country is eligible for a share of revenue generated by the tax. However, the tax is not centrally collected; instead, it's collected on an individual nation basis. This means that countries where MNEs are headquartered or have significant operations will receive the top-up tax revenue.

The goal of the global minimum tax is to ³:

Reduce Tax Competition: Discourage countries from lowering tax rates to attract MNEs and prevent a "race to the bottom."

Prevent Profit Shifting: Stop MNEs from shifting profits to low-tax countries or tax havens, ensuring that profits are taxed where economic activities generating the profits are performed.

Some critics argue that the 15% rate is too low and may not effectively address tax avoidance, while others point out that high-income countries may benefit disproportionately from the new tax revenue .


Why has the US said this was unfair to them?

The US has expressed concerns that the OECD's 15% global minimum corporate tax agreement could undermine US sovereignty and competitiveness. Here are the key reasons ¹ ²:

Impact on US Multinationals: The agreement would require US companies to pay a minimum tax rate of 15% on their foreign earnings, potentially reducing their profitability. This could lead to US companies being at a disadvantage compared to companies from countries that don't adopt the agreement.

Loss of Tax Revenue: The US would have to step in to collect the top-up tax if a US corporation routes its profits through a tax haven and pays less than 15%. This could result in lower tax revenues for the US, as the country would only be able to apply its 35% tax rate to the remaining amount after the 15% tax has been paid.

Restricting US Tax Policy: The agreement could limit the US's ability to reform its own tax system, potentially forcing it to adopt the OECD's framework. This could be seen as an infringement on US sovereignty.

Benefit to European Countries: European countries like France are likely to benefit from the agreement, as it helps curb tax competition between nations. The US, on the other hand, might see its tax revenues reduced.

Existing US Tax Regime: The US already has a relatively high corporate tax rate of 35%, but numerous exemptions and deductions bring the effective tax burden down. The OECD agreement could potentially disrupt this system.

These concerns have led the US to withdraw from the OECD agreement under President Trump's administration, citing the need to protect American businesses and maintain US sovereignty ³.

CASE 1

So a Canadian Multinational Company operating in the US would not be subject to this tax?

A Canadian multinational company operating in the US would be subject to the 15% global minimum corporate tax if:

The company is considered a multinational enterprise (MNE) with consolidated group revenue of at least €750 million ($812 million) in at least two of the four preceding years.

The company's effective tax rate (ETR) in the US (or any other country) is below 15%.

In this case, the US would be considered the "source" country, and the top-up tax would be applied to bring the ETR up to 15%. The tax would be collected by the US government.

If the Canadian MNE's US subsidiary pays a low tax rate due to US tax incentives or other reasons, the top-up tax would be applied to ensure the company pays at least 15% in the US. This ensures that large MNEs operating in the US pay a minimum level of tax on their profits, regardless of their parent company's location .

CASE 2

But the US is not in the agreement...

Since the US has not implemented the OECD's Pillar Two global minimum tax agreement, a Canadian multinational company operating in the US would not be directly subject to the 15% top-up tax under this specific agreement.

However, if the Canadian company has operations in other countries that have implemented the Pillar Two rules, those countries could apply the top-up tax to the company's profits in their jurisdictions if the effective tax rate is below 15% .

The US's non-participation in the agreement means that US-based MNEs are not subject to the same rules, but it may also impact the competitiveness of foreign MNEs operating in the US, as they would need to comply with the rules in other countries where they operate .


What would be the tax standing of my Canadian Multinational in the US?

As the US has not implemented the OECD's Pillar Two global minimum tax agreement, a Canadian multinational company operating in the US would be subject to regular US corporate tax laws.

The company's US subsidiary would pay taxes on its US-sourced income according to the US corporate tax rate, which is currently 21%. The company might also be eligible for various tax credits, deductions, or incentives offered by the US government.

In terms of taxation, the Canadian multinational would:

Pay US corporate taxes on its US-sourced income

Potentially claim tax credits or deductions for foreign taxes paid in Canada or other countries

Be subject to withholding taxes on certain types of income, such as dividends, interest, or royalties, paid to its Canadian parent company

The company's tax obligations in the US would be determined by US tax laws and regulations, as well as any applicable tax treaties between the US and Canada .


Sounds messy...

International taxation can be complex, with multiple countries and tax regimes involved. The interaction between different tax systems, treaties, and regulations can create complexity and challenges for multinational companies.

In this case, the OECD's efforts to establish a global minimum tax aim to simplify and bring more consistency to international taxation. However, the US's non-participation in the agreement adds a layer of complexity for companies operating in the US and other countries that have adopted the new rules .

Saturday, June 28, 2025

Explainer

 Read all about it: Canada's Digital Services Tax... and it kicks in Monday!!

What is Canada's digital services tax — and why does Trump dislike it so much? | CBC News


Copilot:

Are there currently Digital Services taxes on the books anywhere in Europe?

Yes, several European countries currently have Digital Services Taxes (DSTs) in place, even as global negotiations continue under the OECD’s “Pillar One” framework. These national DSTs are typically temporary measures aimed at taxing large digital companies—especially those earning revenue from local users without a physical presence.

๐Ÿ‡ช๐Ÿ‡บ Countries with DSTs in Effect

Here are some notable examples:

France: A 3% DST on revenues from digital advertising, marketplaces, and data sales. It was one of the first to implement such a tax.

Italy: Imposes a 3% DST on digital services revenue earned from Italian users.

Spain: Also applies a 3% DST, targeting online advertising, intermediation services, and data transmission.

Austria: Has a DST focused specifically on digital advertising revenues.

United Kingdom: Introduced a 2% DST in 2020 on revenues from social media platforms, search engines, and online marketplaces that derive value from UK users.

These taxes generally apply only to large multinational firms that exceed certain global and domestic revenue thresholds.

๐Ÿงญ Why They Exist

These DSTs were introduced because traditional tax rules didn’t capture value created by digital business models.

They’re meant to be interim solutions until a global agreement is reached under the OECD’s Pillar One, which aims to reallocate taxing rights more fairly.

⏳ What’s Next?

Although there was hope that DSTs would be phased out by mid-2024 under a global deal, delays in finalizing Pillar One have led many countries to extend or maintain their DSTs for now.

Would you like a quick comparison table of how these DSTs differ across countries?

Please...

Here’s a handy comparison of Digital Services Taxes (DSTs) currently in effect across several European countries:

                                                                 


These DSTs are gross revenue taxes, not profit-based, and are designed to capture value from user engagement in the taxing country—even without a physical presence.

Let me know if you’d like to add Canada or other non-EU countries to the mix for a global view ๐ŸŒ


Could you cover Canada and others as well...

Absolutely, Louise! Let’s zoom out and look at how Canada and other countries are handling Digital Services Taxes (DSTs). Here's a comparative snapshot to give you a global perspective:

                                                                           



๐Ÿ” A Few Observations

Canada’s DST is one of the few that’s retroactive, applying from 2022. That’s a big deal—it’s expected to generate a $2B bill for U.S. tech firms this year alone.

Thresholds vary widely: India and Kenya have very low or no thresholds, while most OECD countries aim squarely at large multinationals.

Scope matters: Some countries (like Austria) narrowly target ads, while others (like Canada and Spain) cast a wider net over user data and marketplaces.

Would you like to explore how these DSTs interact with the OECD’s Pillar One framework—or how companies are responding to this patchwork of rules?


Tell me about the OECD's Pillar One framework...

Absolutely, Louise! The OECD’s Pillar One framework is part of a global effort to modernize international tax rules for the digital age—especially to address how and where large multinational companies (like tech giants) should be taxed.

Here’s a breakdown of what it’s all about:

๐ŸŒ What Is Pillar One?

Pillar One is designed to reallocate taxing rights so that countries where users and consumers are located (the “market jurisdictions”) can claim a share of the profits from large multinational enterprises (MNEs)—even if those companies have no physical presence there.

๐Ÿงฎ Key Components

                                                                               

๐Ÿงญ Why It Matters

Traditional tax rules are based on physical presence, which doesn’t work well for digital businesses.
Pillar One aims to level the playing field by ensuring that countries where value is created (through users and markets) get a fair share of tax revenue.

It’s also meant to replace unilateral DSTs (like Canada’s or France’s), which have caused trade tensions.

๐Ÿ•ฐ️ Status Update

A Multilateral Convention (MLC) to implement Pillar One was published by the OECD in October 2023.

It needs to be ratified by at least 30 countries representing 60% of the affected MNEs before it can take effect.

Progress has been slow—some countries are hesitant, and others (like Canada) are moving ahead with their own DSTs in the meantime.

Would you like to explore how Pillar One interacts with Pillar Two (the global minimum tax), or how companies are preparing for this shift?



Yes...
Great! Let’s dive into Pillar Two, the OECD’s companion to Pillar One—and arguably the more transformative of the two.

๐Ÿงพ What Is Pillar Two?

Pillar Two introduces a global minimum corporate tax rate of 15% for large multinational enterprises (MNEs). The goal is to curb profit shifting to low-tax jurisdictions and ensure that big companies pay a baseline level of tax wherever they operate.

๐Ÿงฎ Key Features of Pillar Two

                                                                            

๐Ÿงฉ How It Works

Calculate ETR in each country where the MNE operates.
If ETR < 15%, a top-up tax is triggered.

That tax is collected either:
By the parent company’s country (Income Inclusion Rule), or
By other countries where the MNE operates (Under-Taxed Payments Rule).

๐ŸŒ Why It Matters

Reduces tax competition: Countries can’t lure companies with ultra-low tax rates without losing revenue.

Levels the playing field: Smaller or domestic firms aren’t disadvantaged by aggressive tax planning.
Complements Pillar One: While Pillar One reallocates taxing rights, Pillar Two ensures a minimum floor for taxation.

๐Ÿ•ฐ️ Current Status

The OECD released the 2025 Consolidated Commentary in May, incorporating the latest guidance.
Over 135 jurisdictions have agreed in principle, but implementation varies.

Some countries (like the U.S.) are still debating how to align domestic law with the GloBE rules.

Would you like a visual summary comparing Pillar One and Pillar Two side by side? Or maybe a look at how Canada is implementing Pillar Two specifically?


Tell me how Canada is implementing Pillar Two...

Canada is moving full steam ahead with implementing Pillar Two, the OECD’s global minimum tax framework, through its new Global Minimum Tax Act, which received royal assent on June 20, 2024. 

Here's how it's rolling out:

๐Ÿ‡จ๐Ÿ‡ฆ Canada’s Pillar Two Implementation at a Glance

                                                                           

๐Ÿงพ What’s Required of Companies?
Registration: Qualifying MNEs must register for a global minimum tax account.

Filing: They’ll need to file one or more forms detailing their global and jurisdictional ETRs.

Compliance: Canada’s rules are designed to closely follow the OECD’s guidance, including safe harbors and dispute resolution mechanisms.

๐Ÿง  Why It Matters

This move positions Canada as one of the early adopters of Pillar Two, aiming to:

Protect its tax base from erosion via profit shifting.

Ensure fairness by leveling the playing field between domestic firms and global giants.

Align with global norms, while retaining sovereignty over domestic tax enforcement.

If you’d like, I can walk you through how this compares to the U.S. approach—or how companies are adapting their tax strategies in response.


What is the US approach? 

The U.S. approach to the OECD’s Pillar Two global minimum tax is… complicated. While the U.S. supports the idea in principle, it hasn’t fully aligned its domestic tax code with the OECD’s GloBE (Global Anti-Base Erosion) rules—at least not yet.

Here’s how things stand:

๐Ÿ‡บ๐Ÿ‡ธ U.S. and Pillar Two: A Hybrid Position

                                                                           

๐Ÿง  What Is GILTI?

GILTI imposes a minimum tax on foreign income of U.S. multinationals.

It was designed to discourage profit shifting to low-tax jurisdictions.

However, it calculates tax on a global average basis, not jurisdiction-by-jurisdiction like Pillar Two requires.

This means a U.S. company could pay less than 15% in one country and more in another, and still avoid a top-up tax under GILTI—something Pillar Two would not allow.

๐Ÿ•ฐ️ What’s Next?

There have been proposals to reform GILTI to make it more Pillar Two–compliant (e.g., country-by-country calculations), but they’ve stalled in Congress.

The U.S. Treasury continues to engage diplomatically with the OECD and other countries, but domestic implementation remains uncertain.

So, while the U.S. has a head start with GILTI, it’s not yet playing by the full Pillar Two rulebook. If you'd like, I can show how this affects U.S. multinationals operating in countries like Canada or France that are enforcing Pillar Two.


Show me...

Here’s how U.S. multinationals are being affected by Pillar Two rules in countries like Canada and France, which are actively enforcing the global minimum tax—even though the U.S. hasn’t fully adopted the OECD framework:

๐Ÿ‡บ๐Ÿ‡ธ U.S. Multinationals Operating Abroad: What’s Happening?

                                                                            

๐Ÿ” Recent Developments

The U.S. Treasury recently reached a tentative agreement with G7 countries (including Canada and France) to exclude U.S. companies from Pillar Two top-up taxes—in exchange for dropping a proposed retaliatory tax provision in U.S. legislation.

However, this agreement only covers Pillar Two, not Digital Services Taxes (DSTs), which remain a flashpoint—especially between the U.S. and Canada.

๐Ÿง  What This Means for U.S. Companies

Without full U.S. adoption of Pillar Two, American multinationals are navigating a patchwork of foreign rules.

They may need to restructure operations, recalculate ETRs jurisdiction by jurisdiction, and prepare for compliance costs in countries enforcing the GloBE rules.

Some are even considering re-shoring holding companies or reorganizing subsidiaries to reduce exposure to UTPRs and top-up taxes.

Would you like a visual map of which countries are enforcing Pillar Two and how that overlaps with DSTs?