A robust set of international corporate tax reforms was unveiled by the Senate Republicans in their version of the reconciliation tax bill, including adjustments to the House-passed version and a suite of new provisions. Among them is a reintroduction to the big-ticket section 899 retaliatory tax, albeit with some watering down after the provision provoked an uproar in the business community and among overseas governments. A&M Managing Director Brendan Sinnott commented on the Senate’s decision to keep the provision, noting it “seems like a tacit acknowledgment that prior pressure the United States has put on pillar 2 adoption has not been enough to curb its implementation.” 

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