President-elect Trump has nominated Scott Bessent to be the next Treasury Secretary in his incoming administration. Bessent had been an advisor to the Trump campaign and has praised the first Trump Administration, saying "We had a great economy under Trump 1.0 [and] we could have a golden age over the next four years."

Trump also named Kevin Hassett to direct the National Economic Council and Jamieson Greer as the US Trade Representative, filling two other key positions on his economic team.

G20 leaders met in Rio de Janeiro during 18-19 November, at the conclusion of which they issued a Leaders' Declaration that touched on international taxation and the BEPS 2.0 project. The declaration describes progressive taxation as key to achieving broader domestic social, fiscal and development objectives and expresses the intention to engage cooperatively on effective taxation of ultra-high-net-worth individuals, referencing the continuation of discussion of these issues in the G20 and encouraging the OECD/G20 Inclusive Framework (IF) to consider working on these issues as well.

The declaration also reiterates the G20 Leaders' commitment to the October 2021 statement on BEPS Pillars One and Two and to swift implementation by all interested jurisdictions. It further notes continuing constructive discussion at the United Nations on the development of a Framework Convention on International Tax Cooperation.

In advance of the meeting, the OECD released the OECD Secretary-General's Tax Report to the G20 Leaders. This report provides an update on activities with respect to the G20's international tax agenda, including ongoing work on the BEPS 2.0 project, tax transparency and capacity-building efforts. A Global Tax Alert provides details.

What action the US may take in response to the global activity on Pillar Two is unclear. The Trump Administration and Republican-controlled Congress will need to decide in the coming months to what degree to participate in the IF's negotiations of the administrative guidance. In that respect, the new US Administration may push to reopen some areas of the Pillar Two administrative guidance. In particular, they may want to block the ability of foreign governments to impose UTPRs on US multinational enterprise (MNE) earnings, beyond the current delay from 2025 to 2026 under the UTPR safe harbor and to make permanent the blended controlled-foreign-companies-push-down guidance, which is helpful to US MNEs.

The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes this week held its 17th Plenary meeting in Asunción, Paraguay, announcing that 61 jurisdictions have committed to implement the Crypto-Asset Reporting Framework (CARF). The group also issued the 2024 Global Forum annual report providing details on the status of global tax cooperation. The Forum further released the OECD Peer Review of the Automatic Exchange of Financial Account Information 2024 Update.