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US international tax policy considerations
The Biden Administration has supported the BEPS 2.0 project, but the US stance on adopting Pillar Two is dependent on the political climate and will be driven in large part by the outcome of the 2024 elections. If Republicans win the presidency or take control of the Senate in 2024, it is unlikely that there will be an appetite to adopt legislation implementing BEPS 2.0.
Complicating matters, the US already has two minimum tax regimes — the global intangible low-taxed income (GILTI) regime and the corporate alternative minimum tax (CAMT) — which both have some key differences from the Pillar Two global minimum tax.
So, will the US continue to go its own way? Will it embrace the Pillar Two rules? Or will it aim for some sort of compromise between the two? The answers may become clearer after the 2024 elections.