US Treasury Revises Global Minimum Tax Rules to Favor American Companies

The US Treasury Department has released revised rules for multinational companies to comply with global minimum tax regulations. The new version of the Global Anti-Base Erosion Information Return (GloBE IR) introduces a 'side-by-side' safe harbor, allowing American companies to opt into compliance primarily under domestic global minimum tax laws.

This change creates a mechanism for US-headquartered groups to sidestep key provisions of the OECD's Pillar Two framework, specifically the Income Inclusion Rule and the Undertaxed Profits Rule, if they're already meeting minimum tax requirements at home.

The revisions also build in explicit protections for US substance-based tax incentives, including safeguards for the R&D tax credit under the new framework.

Treasury Secretary Scott Bessent framed the changes as advancing President Trump's international tax objectives, which differ from those of the Biden administration that pushed for full integration with Pillar Two.