This chapter explores the prospects of Pillar One and Pillar Two. Fundamentally, Pillar One seems destined to fail, while Pillar Two is being implemented by a critical mass of countries. Pillar One is unlikely to succeed for three reasons. First, it requires a multilateral tax convention (MTC) among over 100 countries to be implemented. Second, because Pillar One is still aimed primarily at taxing the US digital giants (Big Tech), it is hard to envisage it being implemented without the United States. Third, Pillar One is premised on all the countries that have adopted DSTs repealing them. But DSTs are politically popular and, in some cases (e.g., the United Kingdom), brought in significant revenue. This chapter discusses options countries may have to tax Big Tech without Pillar One and then addresses the US response. For Pillar Two, it examines how Pillar Two will affect countries that have not adopted it yet, such as China and the United States, and Pillar Two’s impact on domestic tax incentives like tax holidays, accelerated depreciation, and tax credits.