The Treasury Department has announced a deal with G-7 allies that excludes U.S. companies from some taxes imposed by other countries, in exchange for removing the Section 899 “revenge tax” proposal that is included in the ‘One Big Beautiful Bill’ in both the House and Senate versions of the bill.
Treasury Secretary Scott Bessent has stated, “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. Based on this progress and understanding, I have asked the Senate and House to remove the Section 899 protective measure from consideration in the One Big Beautiful Bill,” he added.
The controversial “revenge tax” was drafted by House Republicans with White House support to counter tax measures by several countries that target U.S. firms. Wall Street had feared it would hinder foreign investment.
We will continue to track these developments closely and provide updates as the legislative process continues. If you have any questions or require further information, please contact your WG advisor.
