Treasury Secretary Scott Bessent said June 26 that "we will announce a joint understanding among G7 countries that defends American interests" related to the OECD-led global tax agreement, and therefore he has asked the House and the Senate to remove the new IRC Section 899 retaliatory tax proposal included in the House-passed and Senate-proposed One Big, Beautiful Bill Act (OBBBA, H.R. 1).

The Secretary posted on social media, "OECD Pillar 2 taxes will not apply to U.S. companies, and we will work cooperatively to implement this agreement across the OECD-G20 Inclusive Framework in coming weeks and months … Based on this progress and understanding, I have asked the Senate and House to remove the Section 899 protective measure from consideration in the One, Big, Beautiful Bill."

The House and Senate included different versions of the IRC Section 899 proposal, which were rooted in bills introduced earlier this year by Ways and Means Committee Chairman Jason Smith (R-MO) and Rep. Ron Estes (R-KS) and prompted concerns about investment.

The House version of the proposal that would cap the additional tax at 20% over the statutory rate or treaty rate was estimated to raise $116 billion. The Senate version, with the increase in withholding tax rates of 5 percentage points per year capped at 15 percentage points and all the IRC Section 899 penalty provisions delayed until 2027, was estimated to raise $52 billion.