Trump advances international tax agenda with revised GloBE Information Return

The US Treasury Department has overhauled the Global Anti-Base Erosion Information Return, giving American multinational companies a way to comply with global minimum tax rules without getting crushed by redundant paperwork. The revisions, announced on September 11, create what Treasury calls a “side-by-side” safe harbor, a mechanism that lets US-headquartered groups opt into compliance primarily under domestic global minimum tax laws. In practical terms, that means US companies can now sidestep key provisions of the OECD’s Pillar Two framework, specifically the Income Inclusion Rule and the Undertaxed Profits Rule, if they’re already meeting minimum tax requirements at home. What the revised GIR actually changes The original GloBE Information Return, adopted in January 2025 under the Biden administration, assumed that US corporate groups would need to comply fully with the OECD’s Pillar Two regulations. That created a layering problem: American companies were potentially subject to both domestic minimum tax obligations and overlapping international ones, with all the filing headaches that entails. The new version flips that assumption. Under the safe harbor election, US multinatio...