The Biden administration’s proposal to replace a much-criticized anti-abuse tax with an internationally standardized rule could help allay a point of contention in global digital tax negotiations.
In the $2.25 trillion infrastructure proposal released Wednesday, the administration appeared to put the base erosion anti-abuse tax, or BEAT, on the chopping block—a provision from the 2017 tax law that both companies and other countries view as problematic, according to practitioners. The proposal suggests the U.S. could put in its place an anti-abuse measure—known as the under-taxed payments rule—that’s part of the “Pillar Two” plan being developed by the OECD to help ...