The U.S. Department of the Treasury on September 11, 2026, welcomed a revised GloBE Information Return that puts part of the OECD Pillar Two side-by-side framework into operation. The return provides a mechanism for U.S.-headquartered companies to elect a safe harbor from the Income Inclusion Rule and Undertaxed Profits Rule, while countries continue considering the framework through their domestic legislative processes.

Treasury said the revision implements a key part of President Donald Trump’s international tax agenda and his Day One Executive Order addressing the Biden administration’s proposed OECD global tax deal. According to Treasury, the framework is intended to keep U.S.-headquartered companies subject to U.S. global minimum taxes while avoiding overlapping foreign regimes and duplicative reporting obligations.

The previous GIR, released in January 2025, assumed that U.S.-headquartered companies would be subject to the OECD Pillar Two Global Minimum Tax rules. Treasury said that version would have required those companies to provide extensive financial information about operations in every country where they operate to calculate potential Pillar Two liabilities. In January 2026, Treasury secured an agreement on a side-by-side package with more than 145 countries in the OECD/G20 Inclusive Framework.

Under that package, U.S.-headquartered companies would remain subject only to U.S. global minimum taxes and would be exempt from the Pillar Two cross-border IIR and UTPR through the side-by-side safe harbor. The revised GIR also creates a standardized reporting framework for local minimum taxes based on Pillar Two rules. Its dissemination provisions limit information submitted for a country’s local minimum tax to that jurisdiction rather than allowing it to be shared with other countries.

The revised GIR includes three principal provisions:

  • A field allowing U.S.-headquartered companies to elect the side-by-side safe harbor
  • Specific reporting exemptions for companies making that election
  • Rules protecting substance-based tax incentives, including the U.S. R&D tax credit for foreign-headquartered companies operating in the United States, from Pillar Two top-up taxes

Treasury Secretary Scott Bessent said the return would reduce reporting and compliance burdens while preserving U.S. tax sovereignty. Treasury also said the January agreement was intended to protect critical tax incentives, including the Research and Development tax credit. Countries are continuing to legislate and adopt the side-by-side safe harbor through their normal domestic processes, and Treasury said it would remain engaged with international partners during implementation.