The “One Big Beautiful Bill Act” significantly amends the clean energy provisions that were enacted as part of the Inflation Reduction Act of 2022 (the “IRA”). Although the legislation is not final and could change before final enactment, its impact on the clean energy provisions enacted as part of the IRA warrants attention from investors, developers, manufacturers, and financiers that rely on these provisions.

At the onset of its second term, the Trump Administration made clear that the US opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”). It directed the Secretary of the Treasury together with the United States Trade Representative to investigate any country that is not complying with tax treaties with the US, or countries that adopt laws that, in the Administration’s view, impose extraterritorial taxes or disproportionately affect American companies, with the ultimate goal of implementing retaliatory or protective measures in response.