On 25 August 2021, United States (US) Senate Finance Committee Chairman Ron Wyden and Senators Sherrod Brown and Mark Warner detailed the international tax framework they released in April, focused on changes to the 2017 Tax Cuts and Jobs Act’s provisions on global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT). Newly released legislative text of the framework — the April release did not include legislative language — still leaves several policy options undetermined, including the GILTI tax rate and how the BEAT might be changed to incorporate aspects of the Biden...