Document Type
Article
Publication Date
9-2025
Abstract
On June 26 Treasury Secretary Scott Bessent announced a deal with the G7 to accept the global intangible low-taxed income tax as a valid income inclusion rule tax and not apply the undertaxed profits rule to U.S. multinational enterprises. Bessent said a “joint understanding” among the United States and other countries will be announced soon. “OECD pillar 2 taxes will not apply to U.S. companies, and we will work cooperatively to implement this agreement across the OECD-G20 inclusive framework in coming weeks and months,” Bessent wrote. Soon after, Senate Finance Committee Chair Mike Crapo, RIdaho, and House Ways and Means Committee Chair Jason Smith, R-Mo., announced that they agreed to remove section 899 (the revenge tax) from the pending One Big Beautiful Bill Act (P.L. 119-21). In their joint statement, Crapo and Smith wrote that the agreement would “preserve U.S. tax sovereignty and allow U.S. tax laws to co-exist with the Pillar 2 regime.”
Recommended Citation
Avi-Yonah, Reuven S. "Should the OECD Accpet GILTI as a Valid IIR?" TaxNotes International 119, no. 9 (2025): 1413-1420.
Comments
Reprinted with the permission of Tax Analysts.