Treasury unveils revised GloBE return to ease U.S. companies’ global tax burden

  • Treasury revised the GloBE Information Return for U.S.-headquartered multinational companies.
  • More than 145 countries agreed in January 2026 to the side-by-side framework.
  • The return provides safe-harbor elections, standardized reporting and protections for specified tax incentives.

The U.S. Treasury Department has overhauled the GloBE Information Return (GIR), enabling U.S.-headquartered companies that meet domestic global minimum tax requirements to elect a side-by-side safe harbor from the OECD Pillar Two Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR). Announced on September 11, the revisions implement an agreement reached in January 2026 by more than 145 countries in the OECD/G20 Inclusive Framework. The revised return is intended to prevent overlapping U.S. and foreign minimum-tax obligations, reduce duplicative filings and standardize jurisdictional reporting. It also protects substance-based tax incentives, including the U.S. Research and Development tax credit for foreign-headquartered companies operating in the United States. Technology and manufacturing companies may benefit because of their reliance on R&D incentives, although trading partners could still apply compensatory measures if they view the safe harbor as inconsistent with global minimum-tax commitments.

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