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The Tax Foundation is the nation’s
leading independent tax policy
research organization. Since 1937,
our research, analysis, and experts
have informed smarter tax policy
at the federal, state, and global
levels. We are a 501(c)(3) nonprofit
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Editor, Rachel Shuster
Designer, Dan Carvajal
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Washington, DC 20005
An International Tax Agenda for
Congress on the Anniversary of the
Global Tax Deal
• A year since the global tax deal was agreed to by more than 130 countries,
progress on implementing legislation has hit a lull.
Implementation of the minimum tax rules is not expected until the end of
2023 or in 2024.
• Since the 2017 U.S. tax reforms and other recent international rules changes,
onshoring of intellectual property (IP) to the U.S. has increased and outward
investment strategies for U.S. companies have shifted. This should impact
how the U.S. approaches the global tax deal.
• The international tax reforms included in the Build Back Better Act (BBBA)
do not line up with the global minimum tax model rules and could prove a
complex mess if adopted.
• Congress should prioritize evaluation of recent international tax trends and
the model rules and adjust U.S. rules in a way that supports investment and
innovation and moves towards simplicity.
Executive Vice President
TAX FOUNDATION | 2
It has been a year since more than 130 countries signed up to an outline for international tax reform.1
That outline described ambitious proposals to change the taxation of large multinational corporations
with a shift in their tax base toward market countries alongside a global minimum tax. The two pieces,
known as Pillar 1 (the shift in the tax base) and Pillar 2 (the global minimum tax), will impact the way
large businesses arrange their tax affairs and the way governments desi