international

The OECD’s Global Anti-Base Erosion (GloBE) rules under Pillar II are gaining momentum, with many countries beginning phased implementation through 2025. For U.S. corporations with international operations, understanding these changes is no longer optional.

GloBE introduces a 15% global minimum tax applied on a jurisdictional basis. If a U.S.-headquartered multinational earns profits in a foreign country that taxes below the threshold, a top-up tax may be triggered — even if the U.S. already applies Subpart F or GILTI.

For multinational businesses, the Foreign Tax Credit (FTC) remains a cornerstone of avoiding double taxation. But with the OECD’s Pillar II global minimum tax coming into effect, the path to FTC optimization is more complex than ever.

The FTC allows U.S. taxpayers to offset income taxes paid to foreign governments against their U.S. tax liability. Traditionally, this has mitigated the burden of earning income in high-tax foreign jurisdictions. However, Pillar II introduces new minimum tax rules that may change the calculus.