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Gary D. Sprague

Mr. Sprague was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group ("TAG") on Tax Treaty Characterisation Issues Arising from E-Commerce, and was elected chair of the business representatives on the TAG. He also was appointed by the OECD to serve as the business co-chair on the Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits. He was the Co-General Reporter for the subject Taxation of Income Derived from Electronic Commerce for the International Fiscal Association 2001 Congress, and is a co-author of BNA Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce. He is the General Reporter for the subject Big Data and Tax – domestic and international taxation of data driven business for the International Fiscal Association 2021 Congress. He also is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.

Amount B was introduced as a “fixed return” on “baseline marketing and distribution activities” in the October 2020 Blueprint of Pillar One, and was seen as a critical component of the Pillar One deal
Following the long-awaited release of the consultation document on 8 December 2022 and subsequent public commentary received, the OECD/G20 Inclusive Framework on BEPS published a consultation document on Amount B on 17 July 2023, creating renewed momentum and putting Amount B back into the international tax spotlight.