The Trump administration’s first‑day executive order withdrew the United States from a 13‑year OECD initiative aimed at curbing offshore profit shifting. By abandoning the Pillar 2 framework, U.S. firms reclaimed at least $40 billion, significantly in income taxes since early 2025. A new SEC footnote rule publicly forced nearly 500 public companies to disclose the exact tax savings tied to each foreign jurisdiction.

Companies ranging from Walmart to PayPal rerouted hundreds of billions of dollars through shell subsidiaries in Malta, Cyprus, Bermuda and the Cayman Islands, often without employees or customers. Abbott Laboratories alone saved $336 million by attributing all global profit to a Maltese entity, while American Express avoided $423 million via Jersey. The aggregate avoidance could fund three times the FAA’s annual budget.

The IRS has already challenged more than $1 billion of Abbott’s deductions, arguing they lack economic substance, and tax advisers warn the lax regime will invite even more aggressive schemes. With the minimum‑tax rule stalled in Congress, investors for the market face heightened scrutiny of earnings quality as firms continue to exploit jurisdictions that impose little or no corporate tax.