Disruption, uncertainty and a lack of familiar guideposts draw a challenging landscape for the tax professional. As tax policy shifts, impacted by both US and global tax rules, the path forward becomes muddied. This uncertainty creates both challenges and opportunities. Although the debate surrounding ‘fair share’ has largely focused on ‘digital’ businesses, proposals to change the international tax system under consideration would apply more broadly. The debate over whether multinational enterprises pay an appropriate amount of tax in the countries in which they generate revenue has been a particular focus of certain governments and non-governmental organizations.