What happened The biggest tax project of the decade just bent. Under a "side-by-side" agreement inside the OECD/G20 Inclusive Framework, US-headquartered companies will stay subject only to US minimum taxes while being fully excluded from the two enforcement rules at the heart of the global minimum tax (Pillar Two): the Income Inclusion Rule and the Undertaxed Profits Rule. The more than 145 other countries in the framework continue under Pillar Two.