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June 27, 2025

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2 min read

Section 899 “Revenge Tax” Cut from One Big Beautiful Bill Act

On June 26, 2025, the Treasury Department announced on X that it had reached a deal with the G7 that includes the removal of the proposed Section 899 “revenge tax” from the One Big Beautiful Bill Act of 2025 (the Act) in exchange for an agreement to exempt U.S. companies from certain taxes under OECD Pillar 2. 

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Winston & Strawn’s Tax Impacts series features timely updates and insights impacting taxpayers, spanning from federal, international, and state and local tax planning to controversy.

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James N. Mastracchio

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Susan Elizabeth Seabrook

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