Reconcilable Differences: On the International Tax Provisions in the OB3

On July 4th, President Trump signed the One Big Beautiful Bill (the OB3) —a budget reconciliation bill that included significant tax provisions—into law. The OB3 omitted the controversial “revenge tax” of section 899 after the G7 declared their commitment to adopt a side-by-side system for the U.S. tax system and Pillar 2, but nonetheless included changes that could fundamentally alter impact the U.S. international tax landscape. How does OB3 change GILTI, FDII, BEAT, and foreign tax credit regimes, and do these changes shift the balance between GILTI and FDII? How could the changes to the international tax rules, section 163(j), and section 174 impact BEAT and CAMT?  How could the legislative process for the OB3 change the path of future tax legislation? Is the revenge tax totally dead or just mostly dead?

Join us as our hosts Gary Scanlon and Kristen Gamboa interview returning guest Ron Dabrowski, Principal in Charge of the KPMG WNT International Tax practice, to answer these questions and more on the latest episode of Inside International Tax.