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MemoMemorandumTrump 47 · R Quiet signal

Presidential Memorandum

The Organization for Economic Co-Operation and Development (OECD) Global Tax Deal (Global Tax Deal)

This memorandum declares that the OECD Global Tax Deal has no force or effect in the United States without congressional adoption, directs Treasury and the U.S. OECD representative to formally notify the OECD of this position, and orders Treasury and USTR to investigate foreign extraterritorial or discriminatory tax measures affecting American companies and recommend protective U.S. responses within 60 days.

Federal Register Open PDF 90 FR 8483

Impact dates

  1. Treasury delivers findings and recommendations on protective measures to President

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

Technology & softwarePharmaBanking & financeOther industrial

Mechanisms

TariffBan / prohibitionLicensing

Role pressure

  • MixedDomestic producer — Large U.S. multinationals avoid Pillar Two compliance costs but may face foreign retaliatory tax regimes; domestic-only firms relatively unaffected
  • UncertainImporter — Potential protective measures could include tariff-like responses to foreign digital services taxes or minimum taxes, creating unpredictable trade costs
  • AdverseTrading-partner exporter — Countries with Pillar Two implementation or digital services taxes face potential U.S. protective measures; OECD commitment uncertainty disrupts tax planning

Geographies

USEUUKJPKRINOTHER

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

MMM3MGOOGLAlphabetAAPLAppleBACBank of AmericaBLKBlackRockCATCaterpillarLLYEli LillyFCXFreeport-McMoRanGEVGE VernovaGSGoldman SachsHONHoneywellHSBCHSBCQQQInvesco QQQ TrustJNJJohnson & JohnsonJPMJPMorgan ChaseMRKMerckMETAMeta PlatformsMSFTMicrosoftNVSNovartisORCLOraclePFEPfizerSPYSPDR S&P 500 ETF

Confidence: medium · Policy alerts

Key directives

  • Secretary of Treasury and U.S. Permanent Representative to OECD shall notify OECD that prior U.S. commitments to Global Tax Deal have no force or effect absent congressional adoption
  • Secretary of Treasury and USTR shall take all additional necessary steps within their authority to implement memorandum findings
  • Secretary of Treasury in consultation with USTR shall investigate foreign tax treaty non-compliance and extraterritorial or disproportionately affecting tax rules
  • Secretary of Treasury shall develop list of options for protective measures or other U.S. actions
  • Secretary of Treasury shall deliver findings and recommendations to President through Assistant to the President for Economic Policy within 60 days

Who is ordered

Timeline

Immediate

  • Notification to OECD that prior U.S. commitments to Global Tax Deal have no force or effect
  • Formal repudiation of prior administration's OECD tax policy

Near term (90d)

  • Treasury/USTR investigation of foreign non-compliance with tax treaties and extraterritorial tax rules
  • Delivery of findings and protective measure options to President (within 60 days)

Long term

  • Potential adoption of protective measures or retaliatory actions against discriminatory foreign tax regimes
  • Possible renegotiation of bilateral tax treaties
  • Shift in international tax cooperation dynamics

Risks & tensions

  • Potential trade friction with OECD allies implementing Pillar Two minimum tax
  • U.S. companies may face actual retaliatory tax measures from countries that viewed prior U.S. commitment as stabilizing
  • Unilateral repudiation of multilateral negotiation may weaken U.S. leverage in future international economic forums
  • Congressional adoption requirement creates procedural barrier but also political insulation
  • Vague scope of 'protective measures' could range from diplomatic pressure to tariff-like responses
Presidential Memorandum: The Organization for Economic Co-Operation and Development (OECD) Global Tax Deal (Global Tax Deal) · Executive Orders