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John Warner, shareholder in the firm's Tax section, comments on a letter from the U.S. Treasury Secretary to the Organization for Economic Cooperation and Development regarding concerns about its proposed overhaul to global tax rules. Read "Mnuchin Has 'Serious Concerns' With OECD Digital Tax Plan," in Law360.

John Warner of Buchanan Ingersoll & Rooney PC speculated that the letter was part of the U.S. negotiating stance as terms of the deal are being finalized.

"My reading of Secretary Mnuchin's letter is that the OECD deliberations have probably been going in a direction that is not consistent with the position announced by Assistant Secretary Harter, and is therefore a bit of a veiled threat that the U.S. is serious about limiting the amount of tweaking of the classic arm's-length principal that we will sign onto," Warner wrote to Law360 in an email.