Recent US tax developments - Sec. 891 and Sec. 899 IRC

What this episode covers

In this episode Arne Schnitger and Christian Kaeser welcome Pat Brown, a Partner and Co-leader of PwC's Washington National Tax Services practice. They focus on recent developments relating to US tax policy, particularly Sec. 891 and Sec. 899 of the Internal Revenue Code (IRC). Sec. 891 IRC, enacted in the 1930s and never brought into force until now, allows to double the tax rate on citizens and corporations from countries engaged in extraterritorial and discriminatory taxation against the US. President Trump has authorized an analysis of whether or not countries are engaged in extraterritorial and discriminatory taxation which most likely include the UTPR under Pillar Two. Sec. 899 IRC was a proposed change to the IRC in 2023, is not in force currently and was recently reproposed with some amendments. It aims to address extraterritorial and discriminatory taxation, too. The rule would allow an increase in tax and specifically targeting the UTPR under Pillar Two and Digital Services Taxes. Arne, Christian and Pat talk about the different scope of both Sections, the relation to international tax treaties, the potential impact of the UTPR Safe-Harbours and a possible effective date.

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