Highlights: U.S. International Tax Pillar Two Side-by-Side Guidance

In January 2026, the Organization for Economic Cooperation and Development (OECD) released additional guidance under the Global Anti-Base Erosion Model Rules (Pillar Two). Bloomberg Tax developed this reference to help tax professionals understand key provisions of the guidance that impact U.S. international tax rules, particularly as they apply to U.S.-parented multinational corporations.

Topics include:

  • A summary and exclusive Bloomberg Tax analysis of key provisions
  • Simplified Effective Tax Rate (ETR) Safe Harbor and other compliance measures.
  • Updates on the U.S. GILTI/NCTI framework and its global implications.
  • Actionable insights and planning strategies to ensure your organization remains compliant and competitive in the rapidly changing international tax environment.

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