US Policy and Pillar 2: The Evolution of US Tax Policy Toward OECD Pillar 2 and Its Global Implications

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

2025

Abstract

This paper analyzes the United States’ evolving position on OECD Pillar 2, focusing on the Trump administration’s initial rejection and subsequent negotiations to exempt US multinationals from the Undertaxed Profits Rule (UTPR). It examines the legislative and diplomatic strategies that led to international acceptance of GILTI as a valid IIR. The analysis concludes that the resulting compromise preserves US tax sovereignty while maintaining the global framework’s integrity.

Comments

Reproduced with permission. All rights reserved. Originally published by Novita Fiscali.

Recommended Citation

Reuven S. Avi-Yonah. "US Policy and Pillar 2: The Evolution of US Tax Policy Toward OECD Pillar 2 and Its Global Implications." Novità Fiscali 10 (2025): 532-534.