On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for consideration. The OBBB as passed by the House included minor substantive revisions to three of the international provisions:
- Reduced the section 250 deduction for foreign-derived intangible income and global intangible low-taxed income to 36.5 percent (from 37.5 percent) and 49.2 percent (from 50 percent), respectively;
- Increased the base erosion anti-abuse tax rate to 10.1 percent (from 10 percent); and
- Limited the expanded civil penalty under the Tariff Act of 1930 to violations of US customs law rather than all US law.
For in-depth coverage of the international provisions of the OBBB prior to the revisions mentioned above, see Eversheds Sutherland legal alert: Unpacking the big beautiful international tax provisions of the One Big Beautiful Bill.
Next steps
Now that the House has advanced the OBBB to the Senate, the Senate will take up the OBBB in June after Congress returns from recess. The OBBB is a budget reconciliation bill, which means that the OBBB can be approved by the Senate with a simple majority vote, rather than the typical 60-vote majority that is required. The goal is for both the House and the Senate to pass the OBBB in time for the President to sign it into law on July 4, 2025.
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