Tax Impacts

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. 

Today, President Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). The Act ushers in, among other things, significant changes to the Internal Revenue Code and provides additional resources for the IRS.

The Senate has passed the Inflation Reduction Act of 2022 (“Act”), sending the bill to the House, where lawmakers are expected to take up the bill later this week.

The Act’s passage follows a busy weekend on the Hill, which included lawmakers forging ahead with the comprehensive reconciliation bill with formal debate and the Senate voting Sunday 51 to 50 to pass the reconciliation bill, with Vice President Kamala Harris casting the tie-breaking vote.

Yesterday afternoon, Senator Joe Manchin (D-WV) and Senate Majority Leader Charles E. Schumer (D-NY) announced a last-minute deal—the Inflation Reduction Act of 2022—containing significant changes to federal tax policy and IRS administration.

On July 27, 2022, Senator Joe Manchin (D-WV) and Senate Majority Leader Chuck Schumer (D-NY) announced that they have reached an agreement on a reconciliation package that stems from negotiations on the Build Back Better Act. H.R. 5376, or the Inflation Reduction Act of 2022, would, among other things: (1) establish a 15% corporate minimum tax; (2) provide for increased Internal Revenue Service (“IRS”) enforcement; and (3) modify the carried interest rules to apply short-term capital gains rates.