The U.S. Department of the Treasury released a revised Global Information Return to implement President Trump's international tax agenda and address corporate tax compliance.
The new rules deliver on a Day One Executive Order by exempting U.S.-headquartered companies from overlapping global minimum tax regimes established by the Organization for Economic Co-operation and Development (OECD). Under previous Biden-era rules, U.S. companies would have been subject to extensive financial reporting requirements across all their operations.
In January 2026, the Treasury secured an agreement with more than 145 countries in the OECD/G20 Inclusive Framework to allow U.S. companies to remain subject only to U.S. global minimum taxes. The revised return operationalizes this agreement by providing a mechanism for companies to make an election for the side-by-side safe harbor, which exempts them from the OECD's Income Inclusion Rule and Undertaxed Profits Rule.
The new rules also protect substance-based tax incentives, including the U.S. Research and Development tax credit, from additional Pillar Two top-up taxes.
"The revised GloBE Information Return delivers on a key element of President Trump's international tax agenda by putting the side-by-side framework into operation," Treasury Secretary Scott Bessent said. "It ensures that U.S.-headquartered companies remain subject to U.S. global minimum taxes, not overlapping foreign regimes, while significantly reducing unnecessary reporting and compliance burdens."