House passes the One Big Beautiful Bill Act with minor revisions to the international tax provisions

image of an outdoor balcony in an office during the golden hourimage of an outdoor balcony in an office during the golden hour

House passes the One Big Beautiful Bill Act with minor revisions to the international tax provisions

May 23, 2025

United States
United States
United States
On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for consideration. The OBBB as passed by the House included minor substantive revisions to three of the international provisions:
  • Reduced the section 250 deduction for foreign-derived intangible income and global intangible low-taxed income to 36.5 percent (from 37.5 percent) and 49.2 percent (from 50 percent), respectively;
  • Increased the base erosion anti-abuse tax rate to 10.1 percent (from 10 percent); and
  • Limited the expanded civil penalty under the Tariff Act of 1930 to violations of US customs law rather than all US law.

For in-depth coverage of the international provisions of the OBBB prior to the revisions mentioned above, see Eversheds Sutherland legal alert: Unpacking the big beautiful international tax provisions of the One Big Beautiful Bill.

Next steps

Now that the House has advanced the OBBB to the Senate, the Senate will take up the OBBB in June after Congress returns from recess. The OBBB is a budget reconciliation bill, which means that the OBBB can be approved by the Senate with a simple majority vote, rather than the typical 60-vote majority that is required. The goal is for both the House and the Senate to pass the OBBB in time for the President to sign it into law on July 4, 2025.

__________

If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Services

Client Tools

Key contacts

robbchase@eversheds-sutherland.com

Robert S. Chase II

Partner

Washington, DC, United States

aaronpayne@eversheds-sutherland.com

Aaron M. Payne

Partner

Washington, DC, United States

Latest Insights

Latest News

Latest Events

zero waste new pic

legal updates

November 12, 2026

COP31: Leaders’ Summit | Zero Waste - The business case for zero waste

EV charging COP31

legal updates

November 11, 2026

COP31: Energy and Transport – Electrification takes center stage in Antalya

tracker image - Algorithmic

legal updates

November 11, 2026

Algorithmic Management of Workforces: Is your business a “platform” without...

atrium interior architecture curved levels modern office building design

legal updates

November 10, 2026

Technology Law Shorts - November 2026

© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website. For information on Konexo please also see the Legal Notices page of this website.