Document Type

Article

Publication Date

2025

Abstract

In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah compares House and Senate sections of the One Big Beautiful Bill Act and examines the potential effect on international tax relations. On May 22 the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). The House version of the OBBBA extended the Tax Cuts and Jobs Act tax cuts but did not significantly change its international provisions. It did, however, contain proposed section 899, which would have imposed enhanced taxation on residents and corporations from countries that have “discriminatory or extraterritorial taxes,” defined to include primarily the undertaxed profits rule of pillar 2 and digital services taxes. Thus, the House version of the OBBBA continued the president’s declared rejection of pillar 2.

Comments

Reprinted with the permission of Tax Analysts

Download


Share

COinS