Will Pillar Two Prosper Despite the US Side-by-Side Arrangement?

The OECD's Side-by-Side Package exempts US-parented groups from Pillar Two's Income Inclusion Rule and Undertaxed Profits Rule despite a 14% US minimum tax. Employing doctrinal and structural analysis, this article asks whether the resulting asymmetries undermine Pillar Two's coherence, concluding that the accommodation is permanent, entrenching fragmentation without achieving universality.