2021 Tax Reform: The Substantive Changes Being Proposed

May 25, 2021



Cleary Gottlieb hosted a discussion of the substantive tax law changes proposed in President Biden’s “American Jobs Plan” and “American Families Plan,” and Senator Wyden’s “Framework for Overhauling International Taxation.”

Lawyers from our tax practice addressed how these proposals are the same, how they differ, and how these proposals compare to the OECD’s Pillar 1 and Pillar 2 proposals for taxing international digital profits and imposing a global minimum tax.

Participants also described a few other international tax proposals floating around Congress—you will want to be ready if any of these get pulled into pending legislation late in the process in order to reach a revenue target.


  • William McRae, Partner, Cleary Gottlieb
  • Richard Sultman, Partner, Cleary Gottlieb
  • Diana Wollman, Partner, Cleary Gottlieb
  • Jens Hafemann, Counsel, Cleary Gottlieb