Global Tax Deal Sparks Fear U.S. Law Will Be Tougher to Change

Tax attorney Joshua Odintz was cited in a Bloomberg Tax article surveying practitioners about a new agreement exempting U.S. companies from the Organization for Economic Cooperation and Development's (OECD) Pillar Two global corporate minimum tax. Under the agreement, released January 5, 2026, the U.S. tax system operates alongside the international framework, creating series of "side-by-side" safe harbors that allow companies to avoid the OECD's 15 percent levy while still paying U.S. taxes on domestic and foreign profits. Because the requirements include a 15 percent corporate alternative minimum tax (CAMT) at 20 percent statutory rate, some businesses have expressed concern that future changes to the Internal Revenue Code could jeopardize the country's exempt status. Mr. Odintz echoed these concerns, pointing to questions circulating in the tax community about how the agreement could place constraints on U.S. tax law.

"What if the United States were to try to lower its corporate rate, let's say, to 15 percent, or eliminate its corporate AMT? What happens at that point?" he offered as an example.

READ: Global Tax Deal Sparks Fear U.S. Law Will Be Tougher to Change (Subscription required)