How does the OECD Pillar Two global minimum tax affect foreign-owned U.S. LLCs?
I keep reading about the OECD's Pillar Two framework and a 15% global minimum tax that countries are implementing. My foreign parent company is based in a country that has adopted Pillar Two. We have a U.S. LLC subsidiary. How does Pillar Two interact with the existing U.S. international tax rules like GILTI and BEAT? Could my U.S. LLC be subject to a top-up tax under Pillar Two? I'm trying to understand how these overlapping regimes work.
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