US tax developments - The One Big Beautiful Bill and an update to Sec. 899 IRC after the G7 Statement on Pillar Two

In this episode, Arne Schnitger and Christian Kaeser welcome back
Pat Brown to discuss recent developments in U.S. taxation. Pat, the
Co-Leader of PwC's Washington National Tax Services practice,
provides insights into the history of the proposed Section 899 IRC
within the draft of The One Big Beautiful Bill (OBBB) in the U.S.,
and explains why the proposal was removed following the G7
Statement on Pillar Two. They explore the scope of the G7
Statement, which applies only to U.S. headquartered companies and
excludes the application of the IIR and UTPR in these cases. The
discussion emphasizes the need for meaningful simplifications to
Pillar Two, noting that the QDMTT is still applicable even to U.S.
headquartered companies, while non-U.S. headquartered companies
must adhere to all Pillar Two rules. The response of the European
Commission to the Pillar Two Directive remains to be seen. Finally,
Pat highlights other aspects of the OBBB, such as amendments to the
BEAT, GILTI, and FDII rules, including increased tax rates and
potential benefits for taxpayers.