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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…
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