The groundbreaking global corporate-tax agreement secured last year by Treasury Secretary Janet Yellen included a "failsafe" measure to encourage compliance by its 137 signatories.

That tripwire now looks to be tested by its biggest member economy: the United States.

Just as some negotiators feared, Congress has shown little appetite for enacting the 15 percent worldwide minimum tax. Democratic Senator Joe Manchin—a swing voter in the 50-50 chamber—said this month he's not prepared to go ahead with a legislative package that contains the measure.

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