Treasury Welcomes the Revised GloBE Information Return Implementing President Trump’s Day One Executive Order

New Rules Deliver on President Trump's International Tax Agenda to Protect U.S. Companies from Compliance Burdens

WASHINGTON-The U.S. Department of the Treasury today welcomed the release of the revised GloBE Information Return (GIR), an important step to implementing President Trump's international tax agenda and delivering a historic victory on a Day One Executive Order to address the Biden Administration's proposed Organization for Economic Co-operation and Development (OECD) global tax deal for American companies.

"President Trump made clear on his first day in office that the Biden Administration's OECD global tax deal would have no force or effect in the United States," said Treasury Secretary Scott Bessent. "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. 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. By respecting U.S. tax sovereignty and lowering compliance costs for American businesses, these new rules mark another important step toward restoring certainty and stability to the international tax system."

The agreement was intended to avoid overlapping global minimum tax regimes, reduce associated reporting obligations for U.S.-headquartered companies, and protect the value of critical tax incentives like the Research and Development (R&D) tax credit.

BACKGROUND

The Biden-era GloBE Information Return (GIR), released in January 2025, assumed U.S.-headquartered companies would be subject to the OECD Pillar Two Global Minimum tax rules and therefore would have required U.S. companies to provide extensive financial information regarding their operations in every country in which they operate to calculate potential Pillar Two tax liabilities.

In January 2026, Treasury secured an agreement to the side-by-side package with the more than 145 countries in the OECD/G20 Inclusive Framework to have U.S.-headquartered companies remain subject to only U.S. global minimum taxes while exempting them from Pillar Two cross-border taxes, including the side-by-side safe harbor for U.S.-headquartered companies. Under the side-by-side safe harbor, U.S.-headquartered companies are exempted from the Pillar Two cross-border taxes, specifically the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR).

This agreement ensured that U.S.-headquartered companies would not be subject to two overlapping global minimum taxes and the tax burden and duplicative reporting that would have resulted. The revised GIR provides the mechanism for U.S.-headquartered companies to make the side-by-side safe harbor election and reflects a critical part of implementing the side-by-side framework. It also establishes a standardized reporting framework for local minimum taxes based on the Pillar Two rules while limiting the dissemination of information reported for those purposes to the relevant jurisdiction.

REVISED GLOBE INFORMATION RETURN

The side-by-side framework was designed to relieve U.S.-headquartered companies from both the tax burden of overlapping global minimum tax regimes and the compliance burden associated with duplicative reporting. The revised GIR operationalizes a critical part of that framework by streamlining reporting obligations for U.S.-headquartered companies while preserving the United States' tax sovereignty. The revisions provide the mechanism for U.S.-headquartered companies to make the side-by-side safe harbor election and remove the potential for duplicative compliance obligations.

In addition to enabling the side-by-side safe harbor election, the revised GIR will serve as a standardized reporting mechanism for local minimum taxes based on the Pillar Two framework. The revised return includes dissemination rules that ensure information provided for purposes of a country's local minimum tax is shared only with that jurisdiction and not with any other country. Standardized reporting will help companies avoid a multiplicity of local reporting requirements while streamlining compliance with local minimum taxes.

The key provisions of the revised GIR include:

• Adding a field for U.S.-headquartered companies to make the election to apply the side-by-side safe harbor, thereby exempting them from Pillar Two's IIR and UTPR.
• Providing specific exemptions from reporting for companies that elect the side-by-side safe harbor.
• Allowing taxpayers to apply the new rules protecting substance-based tax incentives that were also part of the side-by-side package, including-in the case of foreign-headquartered companies operating in the United States-the U.S. R&D tax credit, from Pillar Two top-up taxes.

Countries continue to legislate and adopt the side-by-side safe harbor into their domestic law through their normal legislative processes. Treasury will continue to engage closely with international partners as implementation continues.

Global Anti-Base Erosion Model Rules (Pillar Two) | OECD

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