2026

The Treasury Department announced an agreement with OECD Inclusive Framework members confirming that certain U.S.-headquartered multinational groups will be exempt from key elements of the Pillar Two global minimum tax regime. The announcement reflects ongoing efforts to align the Pillar Two framework with existing U.S. tax rules, including the treatment of GILTI. Treasury emphasized that the agreement preserves U.S. taxing rights while reducing the risk of double taxation for U.S. multinationals operating abroad. The development has important implications for the future interaction between U.S. international tax law and the OECD’s global minimum tax project.

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This press release announces that the 147 members of the OECD/G20 Inclusive Framework have agreed on key elements of a package advancing the coordinated operation of the global minimum tax, which includes the side-by-side approach reflected in the Tax Notes article

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US business groups and lawmakers welcomed an agreement reached by over 140 countries at the OECD that would exempt American companies from major parts of the global minimum tax framework.

The Trump administration notched a major win for US companies, securing a commitment from international negotiators at the OECD to exempt them from key provisions of the global minimum tax.

Last year was supposed to mark the moment international trade was dismantled. President Donald Trump’s tariffs, we were told, were so unprecedented in scale and ambition that they might stop globalization in its tracks.

This article evaluates how the G7’s Pillar Two statement could affect the application of minimum tax rules to U.S.-parented multinational enterprises

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Countries at the United Nations are looking at sweeping changes to transfer pricing rules as they design a tax treaty acceptable to developing economies. But easing access to transfer pricing information could emerge as a more realistic outcome.

Summarizes Ireland’s 2026 budget tax measures, including extensions of credits and reliefs affecting individuals and businesses.

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Examines the European Union’s 2026 tax priorities, highlighting the growing role of soft law, administrative coordination, and simplification efforts alongside carbon border and minimum tax initiatives.

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