United States of America: US participation in OECD/G20 Inclusive Framework Multilateral Convention to Implement Amount A of Pillar One (Pillar One MLC) terminated by Presidential Memorandum

On 20 January 2025, the President of the United States adopted a Memorandum on the Organisation for Economic Co-operation and Development's (OECD) Global Tax Deal. The Memorandum declares that prior commitments made by the United States regarding the OECD Global Tax Deal, which would allow extraterritorial jurisdiction over US income and would limit the sovereignty of national tax policy, have no legal effect unless ratified by Congress. This includes the draft OECD/G20 Inclusive Framework Multilateral Convention to Implement Amount A of Pillar One (Pillar One MLC). The Presidential Memorandum directs the Secretary of the Treasury and the Permanent Representative to the OECD to notify the organisation of this position. Additionally, the Secretary of the Treasury, in consultation with the United States Trade Representative, is tasked with investigating foreign tax measures that may disproportionately affect American companies and presenting protective action options to the President within 60 days.