EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition:  US government shutdown continues, new CR possible – Treasury official says shutdown will not affect OBBBA guidance – IRS taxpayer obligations unchanged amid shutdown – IRS FIRPTA proposed regs would remove domestic corporation look-through rule – IRS plans to issue proposed regs on sourcing of ‘borrower fees' in securities lending and sale-repurchase transactions – President Trump ends trade talks with Canada – OECD issues new TP country profiles.

A review of the week's major US international tax-related news. In this edition:  US Government shutdown continues; Republicans offer Democrats a vote on ACA credits – G20 Finance Ministers and Central Bank Governors meeting in Washington discusses BEPS 2.0.

A review of the week's major US international tax-related news. In this edition:  US federal shutdown continues – IRS furloughs nearly half its workforce; first-ever IRS CEO named – US, Brazil sign CAA on spontaneous information exchange – OECD official discusses BEPS 2.0 status – Upcoming OECD tax projects reviewed.

A review of the week's major US international tax-related news. In this edition:  US Congress fails to pass CR to fund federal government – Senate Finance Committee holds digital tax hearing – US digital assets filing deadline 15 October – IRS partially withdraws, revises proposed CAMT regulations – IRS withdraws proposed spinoff regulations – IRS releases 2025-2026 Priority Guidance Plan – Trump Administration announces new tariff plans.

A review of the week's major US international tax-related news. In this edition:  US Congress faces FY funding deadline – IRS to issue notices on international OBBBA provisions effective in 2025 by year-end – IRS GLAM: BPT relief available under US treaty for business profits earned by reverse foreign hybrid – OECD releases review on BEPS Action 13 on CbCR.

A review of the week's major US international tax-related news. In this edition:  US Congress fails to pass CR to fund federal government – Trump Administration to release first IRS Priority Guidance Plan soon – Eighth Circuit vacates Tax Court TP decision in Medtronics – USTR initiates public review of USMCA – US Customs and Border Protection releases updated guidance on US-Japan trade agreement – President Trump signs EO on trade and security agreements – OECD releases report on revised BEPS Action 5 transparency framework.

A review of the week's major US international tax-related news. In this edition:  US Congress moving toward a temporary CR to fund the government, followed by year-end spending bill – Treasury open to revisiting Section 899 retaliatory tax if countries fail to amend BEPS global minimum tax framework – Treasury Secretary warned by some in Congress not to dilute CAMT – US Supreme Court accepts President Trump's tariff policy case, oral arguments week of 3 November.

A review of the week's major US international tax-related news. In this edition:  US Congress returns to FY 26 funding deadline, possible tax legislation – Federal Circuit rules against Trump Administration's tariff policy – President Trump issues Executive Order on US-Japan trade agreement.

A review of the week's major US international tax-related news. In this edition:  US Congress returns following August recess to address FY 26 budget deadline, possible second reconciliation bill – Canada reduces retaliatory tariffs on US goods – US ups tariff rate on India to 50%.

A review of the week's major US international tax-related news. In this edition:  US announces plans for proposed rules on transfer of US real property interests – US issues notice on proposed removal of final DPL rules – IRS announces CAP application period for 2026 – President Trump announces framework for US-EU trade negotiations – Tax press reporting on draft OECD document on possible changes to BEPS Pillar Two global minimum tax.

A review of the week's major US international tax-related news. In this edition:  US IRS Commissioner being replaced by dual role Treasury Secretary – US extends suspension of higher tariffs on China to 10 November – Australia High Court rules in Pepsico royalty withholding, DPT case – UN Committee wraps up August meetings on Framework Convention on International Tax Cooperation.

A review of the week's major US international tax-related news. In this edition:  US Congress enters August recess; government funding necessary, speculation about a fall tax bill – New US tariff policy in force – US imposes additional tariffs on India. 

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans want second budget reconciliation bill in the fall – IRS issues interim CAMT guidance for partnerships – President Trump announces new tariff regime, major trade deals – White House releases comprehensive digital asset framework report – OECD releases XML Schemas and User guides on global minimum tax and CARF. 

A review of the week's major US international tax-related news. In this edition:  US House Republicans working on second budget reconciliation bill – US Treasury official comments on G7 statement on global minimum taxes – G20 communique addresses BEPS – US reaches trade agreement with Japan. 

A review of the week's major US international tax-related news. In this edition:  US ‘One Big Beautiful Bill' international tax changes require immediate review – Congress turns to cryptocurrency – OECD officials offer insights on coming tax priorities – UN committee issues draft notes on tax cooperation framework convention. 

A review of the week's major US international tax-related news. In this edition:  US enacts budget reconciliation legislation with major international tax changes – G-7 issues statement on global minimum taxes to address US concerns – President Trump issues EO extending country-specific tariff deadlines, sends ‘tariff letters' to 14 countries – Canada rescinds DST to preserve US trade talks – IRS revokes crypto-reporting final regulations – IRS announces 83 pieces of guidance obsolete. 

A review of the week's major US international tax-related news. In this edition:  US Senate delays consideration of budget reconciliation bill – Treasury Secretary requests Congress pull retaliation tax proposal from pending tax bill – Senate confirms new Treasury Assistant Secretary for Tax Policy – OECD updating portions of Chapter Vll of the Transfer Pricing Guidelines, studying global mobility issues. 

A review of the week's major US international tax-related news. In this edition:  US Senate Finance Committee releases tax section of Senate Republicans' version of the House budget reconciliation bill; major international changes – IRS announces improvements to Pre-Filing Agreement program. 

A review of the week's major US international tax-related news. In this edition:  US Senate Finance Committee release of tax and health budget reconciliation provisions imminent -- Senate approves new IRS Commissioner – IRS issues interim CAMT guidance – IRS releases Notice on digital asset transactions. 

A review of the week's major US international tax-related news. In this edition:  US Senate moving forward on budget reconciliation legislation – Senate Finance Committee reports out nomination of new IRS Commissioner – President Trump increases tariffs on aluminum and steel imports – Treasury official warns US will act if OECD fails to accept US law as compliant with global minimum tax initiative – OECD releases CRS consolidated text for automatic exchange of financial account information in tax matters. 

A review of the week's major US international tax-related news. In this edition:  US House-passed budget reconciliation bill moves to Senate – US Appeals Court temporarily reinstates tariffs stayed by trade court – Treasury will not release final CAMT regulations anytime soon. 

A review of the week's major US international tax-related news. In this edition:  US House passes budget reconciliation bill, moves to Senate for consideration – Treasury official comments on BEPS Pillar Two permanent safe harbor.

A review of the week's major US international tax-related news. In this edition:  US House Ways & Means Committee reports out $3.8t budget reconciliation bill, but stalls in Budget Committee – OECD releases Consolidated Commentary on GLoBE Model Rules.

A review of the week's major US international tax-related news. In this edition:  US House Ways and Means and Energy and Commerce Committees to begin budget bill markup,  reconciliation package may be scaled back – US international tax bill introduced – US-UK trade framework announced, details to be finalized in coming weeks.

A review of the week's major US international tax-related news. In this edition:  Trump Administration, Congressional Republicans push budget reconciliation deadline to early July – US House committees marking-up draft reconciliation legislation – Treasury Secretary outlines trade policy plan – IRS reissues interim guidance on Advance Pricing Agreement submissions – New IRS Chief Counsel named.

A review of the week's major US international tax-related news. In this edition:  US Congress to begin push to draft budget reconciliation legislation – Treasury official also assumes role as acting IRS Commissioner – US discussing how GILTI can coexist with OECD BEPS 2.0 Pillar Two rules – USTR announces actions regarding Chinese maritime and logistics sectors.

A review of the week's major US international tax-related news. In this edition:  US Congress to move on budget reconciliation after recess – IRS withdraws regulations on certain partnership related-party basis-shifting transactions – OECD/G20 IF on BEPS issues statement following meeting, OECD official comments on discussions – UN negotiating committee of Framework Convention on International Tax Cooperation releases roadmap and guidelines – US launches investigation into pharmaceuticals and semiconductors.

A review of the week's major US international tax-related news. In this edition:  Congress to begin budget reconciliation drafting following two-week recess – US pauses additional country-specific tariff rates, increases tariffs on China – President Trump signs repeal of crypto-reporting final regulations – IRS requests submissions for 2025-2026 Priority Guidance Plan.

A review of the week's major US international tax-related news. In this edition:  US Senate releases FY2025 budget resolution; vote pending – President Trump announces far-reaching trade agenda, including 10% universal tariffs and country-specific ad valorem tariffs.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans moving forward on budget reconciliation – President Trump announces 25% additional import tariffs on automobiles and automobile parts – House Ways and Means Republicans reintroduce “Unfair Tax Prevention Act” in response to Pillar Two – IRS releases 26th annual APA report – US, Swiss competent authorities agree to extend treaty benefits to certain pension, retirement arrangements.

A review of the week's major US international tax-related news. In this edition:  President Trump to receive recommendations for US response to BEPS Pillar One and Two – Congress will resume budget reconciliation work following recess.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans coalescing around single budget reconciliation bill – Congress poised to pass CR to fund the government – Congress votes to repeal IRS final regs on ‘DeFI' digital asset reporting – Trump Administration selects Washington Council Ernst & Young's Rebecca Burch to be Treasury Deputy Assistant Secretary for International Tax Affairs.

A review of the week's major US international tax-related news. In this edition:  President Trump calls for permanent tax cuts during joint session of Congress – Trump Administration imposes tariffs on Canada and Mexico, then reverses – US House Ways and Means Committee set to begin drafting budget reconciliation bill to extend expiring TJCA provisions – US Congress to address expiration of government funding on 14 March – Senate votes to repeal Biden-era regulation requiring some cryptocurrency reporting.

A review of the week's major US international tax-related news. In this edition:  US House passes FY'25 budget resolution, provides framework for reconciliation bill – White House memo sets stage for DST action – Trump administration to review US-PRC income tax treaty – IRS acting commissioner retires, replaced with COO – OECD releases consolidated report on Pillar One Amount B.

A review of the week's major US international tax-related news. In this edition:  President Trump endorses House Budget Committee's FY 2025 budget resolution – Trump Administration expected to release details on US DST action – White House issues EO on regulatory review process – President Trump comments on forthcoming auto and semiconductor chip tariffs.

A review of the week's major US international tax-related news. In this edition:  US House Budget Committee approves FY'25 Budget Resolution in first step to budget reconciliation legislation – President Trump signs country-by-country reciprocal trade and tariffs memorandum – OECD updates main documentation package for MNEs participating in ICAP risk assessments.

A review of the week's major US international tax-related news. In this edition:  President Trump meets with House Republicans to discuss tax bill framework – US tariffs on Canada and Mexico delayed – President Trump signs EO on regulations repeal – IRS GLAM clarifies government position on arm's length standard – US withdrawing from UN talks on international tax cooperation framework.

A review of the week's major US international tax-related news. In this edition:  US House leadership offers budget reconciliation timeline – Recent Trump Executive Order on OECD global tax deal may not necessarily affect IRS guidance on BEPS Pillar One Amount B – Hungary's PM authorizes US tax treaty negotiation.

A review of the week's major US international tax-related news. In this edition:  President Trump signs Executive Orders on BEPS project and trade policy – US House Ways & Means Committee Chairman introduces bill to punish countries imposing discriminatory taxes against US companies – President Trump addresses Davos Economic Forum on US taxation – IRS Commissioner resigns effective 20 January.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump to usher in new administration on 20 January – US House passes Taiwan tax bill – US officials address CAMT guidance – US, France issue statement on exchange of CbC reports for 2024 and 2025 – US officials comment on BEPS 2.0 project – OECD IF co-chairs provide status report on Pillar One Amount A and B – OECD compiling list of related-party transactions used to thwart Pillar Two global minimum tax – OECD releases three packages of BEPS Pillar Two 2.0 global minimum tax guidance.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump open to two budget reconciliation bills, prefers one – House W&M Committee leaders introduce Taiwan tax bill – IRS issues comprehensive package on classification, sourcing of digital content and cloud transactions – IRS releases final regulations on DPLs, extending BEPS Pillar 2 transition relief for DCLs – Final rules released on certain partnership related-party basis shifting transactions – IRS CCA addresses transaction reducing future GILTI inclusion.

A review of the week's major US international tax-related news. In this edition:  US House and Senate return to Washington, House retains Johnson as Speaker – Congressional Republicans lack unanimity on path forward for budget reconciliation – IRS releases technical corrections to CAMT regulations – IRS issues final consolidated return regulations – Cryptocurrency guidance released – IRS will apply economic substance doctrine to transfer pricing cases – UN General Assembly approves resolution on terms for UN Framework Convention on International Tax Cooperation.

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans continue to hold differing views on 2025 budget reconciliation – US to adopt OECD's Amount B simplified and streamlined approach to intercompany transactions beginning 2025 – US announces partial suspension of 1973 US-USSR tax treaty application to Belarus – US international tax officials leaving government – OECD BEPS project update – OECD releases pricing automation tool and fact sheets to implement BEPS Pillar One Amount B – OECD releases peer review report on Action 5 exchange of tax rulings.

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans consider plans for budget reconciliation bills in 2025 – Congress must pass government funding by 20 December, US-Taiwan tax bill still possible – IRS issues final and proposed FX regulations – US-Norway CAA released – IRS requests comments on APA and mutual agreement procedures.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans consider budget reconciliation options to enact legislative agenda – Congress to address government funding that expires on 20 December 2024 – President-elect Trump nominates new IRS Commissioner – IRS releases long-awaited PTEP proposed regulations – Cyprus clarifies exchange of CbC reports with US.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump nominates Treasury Secretary, fills out economic team G20 Leaders' Declaration addresses international tax and BEPS 2.0 project OECD Global Forum on Transparency / Information Exchange announces 61 jurisdictions joining CARF

A review of the week's major US international tax-related news. In this edition: Congressional Republicans eye two budget reconciliation bills in 2025 to enact tax legislation – OECD holds Tax Certainty Day, releases 2023 MAP and APA statistics.

A review of the week's major US international tax-related news. In this edition: Republican US election sweep likely means TCJA extension via reconciliation, BEPS 2.0 project uncertainty – Final IRS Section 987 FX gain / loss regulations release before year-end – IRS comments on new passthrough field unit organization – IRS will permit digital asset transaction reporting on schema, not IRS Form 1042-S – IRS official says companies that ignored TP compliance letters referred for examination.

A review of the week's major US international tax-related news. In this edition: US 2024 election to have major impact on US tax policy – IRS to issue PTEP, Section 987 FX guidance by year-end – US to release notice on voluntary “Amount B”.

A review of the week's major US international tax-related news. In this edition: US announces tax agreement negotiations with Taiwan – IRS launches new LB&I pass-through field operations unit, EY's Jeff Erickson chosen to lead – IRS announces new FATCA relief for FFIs – US officials discuss coming changes to CAMT regs – IRS official recommends expanding OECD Treaty Article 25 MAP scope – OECD official offers BEPS IF update.

A review of the week's major US international tax-related news. In this edition: US House legislators urge Taiwan tax negotiation – IRS launches new LB&I passthrough field operations unit – IRS official discusses CAMT campaign – OECD releases tax report to G20 Finance Ministers and Central Bank Governors.