A&O Shearman

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars

Ralph Cunningham, July 16 2025