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Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two

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The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more

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New Section 899 – Enforcement of remedies against unfair taxes

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On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

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