In this episode of Cross-border Tax Talks, Doug McHoney and Pat Brown discuss the latest developments in US tax policy, focusing on the "One Big Beautiful Bill Act" (OB3) and its implications. They delve into the legislative process, the potential for the bill to pass by July 4th, and the consequences if it fails. A significant portion of the discussion is dedicated to Section 899, which addresses concerns about the Pillar Two UTPR and digital services taxes, including its potential impact on US BEAT regime and international tax treaties. The conversation also covers Treasury's negotiating positions on the UTPR, non-refundable credits, and the treatment of R&D credits, offering insights for US multinationals and inbound investors navigating these complex tax issues.
