Executive summaryOn 25 August 2021, United States (US) Senate Finance Committee Chairman Ron Wyden, along with Senators Sherrod Brown and Mark Warner, issued a discussion draft of legislative text (Discussion Draft) detailing their previously released April 2021 international tax framework, which would amend the current rules on global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), the Base Erosion and Anti-Abuse Tax (BEAT), and other rules.As discussed in more detail below, while many practical and policy details remain to be determined, the Discussion Draft would:Establish a mandatory country-by-country high-tax exclusion (HTE) system for GILTI, subpart F, and foreign branch incomePotentially extend...