News

On June 26, 2025, Scott Bessent, U.S. Secretary of the Treasury, announced a deal with U.S. G7 allies to remove proposed Section 899 from the One Big Beautiful Bill Act in exchange for U.S. companies being shielded from the impacts of the “extraterritorial taxes” imposed by Pillar Two of the Organization for Economic Co-operation and Development’s (“OECD”) Global Anti-Base Erosion Model Rules.

Secretary Bessent made the following announcement on X, formerly known as Twitter:

“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. I want to thank my G7 counterparts for their partnership and collaboration towards achieving this historic outcome. 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.”

Speaker of the U.S. House of Representatives Mike Johnson (R-Louisiana) and U.S. Senate Majority Leader John Thune (R-South Dakota) have not publicly commented on Secretary Bessent’s announcement but are widely expected to remove proposed Section 899 from the One Big Beautiful Bill Act in accordance with the Secretary’s request.

All provisions of the One Big Beautiful Bill Act are subject to change until final passage by the U.S. House of Representatives and the U.S. Senate. Any clients or potential clients of Michael Best & Friedrich LLP that are interested in further discussing the tax provisions of the One Big Beautiful Bill Act should reach out to one of the authors of this Client Alert.