Washington, D.C. (September 5, 2025) – As a result of the G7 agreement between the U.S. and the G7 countries on Global Minimum Tax, the Association of International Certified Professional Accountants has submitted a letter requesting guidance and making recommendations on Pillar Two framework co-existing with U.S. tax rules for U.S. Multinational Enterprises (MNEs) in a side-by-side system to the Organisation for Economic Co-operation and Development (OECD). The letter provides recommendations on the timing of the guidance as well as on substance-based non-refundable tax credits, such as the U.S.’s section 41 research credit.
The G7 statement is a proposed agreement between the U.S. and other G7 countries to protect U.S. MNEs from certain international tax rules that could make them pay extra taxes in other countries, doubling their tax burdens. The rules are part of the Pillar Two framework, which is meant to stop companies from avoiding taxes by shifting profits to low-tax countries. However, the way the rules are written could unfairly hurt U.S. companies.
Additionally, the current rules are confusing and expensive for companies to maintain compliance. Tax credits, such as the section 41 research credit, are treated unfairly when compared to similar credits in other countries, which could discourage innovation and investment in the U.S.
The Association is requesting the following:
Clear and consistent guidance from global tax authorities.
Fair treatment of U.S. tax credits.
Quick action to help companies avoid unnecessary costs and confusion.
“The G7 agreement has been broadly welcomed by the U.S. business community, however until the agreement is finalized, companies must continue to comply with the reporting obligations,” said Reema Patel, Senior Manager for Tax Policy & Advocacy with the Association. “The Association recommends the OECD and Treasury issue harmonized guidance to minimize unnecessary administrative and reporting costs for U.S.-based MNE groups.”
About the Association of International Certified Professional Accountants, AICPA, and CIMA
The Association of International Certified Professional Accountants (the Association) advances the reputation, employability, and quality of CPAs, CGMA designation holders, and accounting and financial professionals globally. Founded in 2017 by the AICPA and CIMA, it represents 580,000 AICPA and CIMA members, candidates, and registrants in more than 150 countries and territories, advocating for the public interest and business sustainability on current and emerging issues.
The American Institute of CPAs (AICPA) is the world’s largest member association representing the CPA profession. It sets ethical standards for the profession and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It also develops and grades the Uniform CPA Examination and builds the pipeline of future talent for the public accounting profession.
The Chartered Institute of Management Accountants (CIMA) is the world’s leading and largest professional body of management accountants. CIMA works closely with employers and sponsors leading-edge research to ensure its members remain the employers’ choice when recruiting financially trained business leaders.
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Contact: Veronica L. Vera
202-434-9215
Veronica.Vera@aicpa-cima.com