Talking Tax Treasury Is Working to Implement GOP Tax Law Amid Shutdown
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Oct 22, 2025 Beth Bell, a former Treasury official with extensive experience in multilateral tax negotiations, now serves as a principal at PwC's National Tax Service. In this discussion, she reveals the Treasury's efforts to implement GOP tax law despite the government shutdown. Bell analyzes the timeline for the U.S. Pillar Two coexistence and cautions companies to adhere to current rules until final legislation emerges. She also addresses the potential reintroduction of Section 899 and what factors might influence congressional actions on tax policy.
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U.S. Pushes For A Side-By-Side Solution
- The U.S. seeks a side-by-side exemption from OECD Pillar Two rules to avoid full adoption of the multilateral system.
- Achieving political agreement in WP11 by mid-November is ambitious but strategically important.
Don’t Let Political Promises Replace Legal Compliance
- Treat political commitments as informative but not legally binding for compliance decisions.
- Continue following existing rules until laws are changed and formal legal clarity appears.
Section 899 Remains A Political Sword
- Section 899 (the "revenge tax") still looms in Congress and shaped prior international negotiations.
- Lawmakers may reintroduce it if the inclusive framework fails to satisfy U.S. concerns by year-end.