U.S. to Remove Proposed Section 899 Revenge Tax Following Agreement with G7 Countries to Exclude U.S. Companies from Pillar 2 Taxes

U.S. Treasury Secretary Scott Bessent has announced a joint understanding (agreement) with the other G7 countries to exclude US companies from Pillar 2 taxes, with plans to implement the agreement across the OECD-G20 Inclusive Framework in the coming weeks and months. Based on this, Secretary Bessent has asked the Senate and the House to remove the proposed Tax Code Section 899 in the One, Big, Beautiful Bill. Among other things, Section 899, "Enforcement of Remedies Against Unfair Foreign T…