The Bottom Line
Treasury Secretary Scott Bessent announced that the United States reached a deal with G-7 countries that excludes U.S. companies from the Organisation for Economic Cooperation and Development’s (OECD) Pillar 2 taxes. According to various lawmakers in the U.S., Pillar 2 allows G-7 countries to tax U.S. firms in a discriminatory fashion.1
As a result of this deal, Bessent asked Speaker of the House Mike Johnson (R-LA) and Senate Majority Leader John Thune (R-SD) to remove the “revenge tax” provision from the House and Senate versions of the One Big Beautiful Bill Act (OBBBA). House Ways and Means Committee Chair Jason Smith and Senate Finance Committee Mike Crapo released a statement confirming that the provision’s removal from both versions of the bill.
The “revenge tax” provision in each of the bills would have allowed a suite of tax hikes against countries that the U.S. deems to be leveling discriminatory taxes against U.S. firms. Each bill proposed adding Section 899 to the Internal Revenue Code which would assess a maximum 20% tax against companies in targeted countries and expose the companies to an amplified base erosion and anti-abuse tax (BEAT).
As the Senate version of the OBBBA works its way through the Senate’s legislative process, Forvis Mazars can help you and your business navigate the changing legislative landscape. Forvis Mazars maintains a legislative tracker that provides updates on the content of the various versions of the reconciliation bill as it moves through Congress. Additionally, Forvis Mazars offers a variety of other educational resources on our website.
- 1“Treasury Deal Halts ‘Revenge Tax’ That Spooked Wall Street,” bloomberglaw.com, June 26, 2025.