EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition:  US House and Senate to resume budget reconciliation process – IRS reinstates "significant issue" letter ruling program – US Court of International Trade rules against Trump Administration's temporary 10% global tariffs – US Trade Representative releases annual Special 301 Report on global IP.

A review of the week's major US international tax-related news. In this edition:  US Congress passes FY'26 budget resolution to prepare targeted budget reconciliation bill – US, Croatia sign tax protocol – Financial institutions should confirm account holders' tax IDs for FATCA and CRS compliance – OECD releases Global Minimum Tax Implementation Toolkit, updated FAQs on GloBE and global minimum tax.

A review of the week's major US international tax-related news. In this edition:  US Senate approves budget reconciliation resolution – House Ways and Means Committee addresses DSTs at trade hearing – US Treasury official discusses Pillar Two side-by-side agreement.

A review of the week's major US international tax-related news. In this edition:  US congressional Republicans eye action on narrow budget reconciliation bill – US, Croatia conclude negotiations on tax protocol – OECD Secretary-General issues tax report to G20 Finance Ministers and Central Bank Governors – Inclusive Framework jurisdictions to develop system to review enacted Pillar Two measures – OECD plans public consultation on transfer pricing for intragroup services – OECD looking to US Treasury's pending crypto reporting regulations as it considers changes to CARF.

A review of the week's major US international tax-related news. In this edition:  US Congress returning from recess as Republicans consider second budget reconciliation option – UN Tax Committee announces tax subcommittee and ad hoc group workplans – WTO fails to extend Moratorium on Customs Duties and Electronic Transmissions – US, UK announce final agreement on drug pricing; preferential treatment for UK pharmaceutical exports.

A review of the week's major US international tax-related news. In this edition:  Trump Administration releases proposed FY'27 budget – Congress recesses as Republicans mull second budget reconciliation bill – IRS releases 27th annual APA report – White House issues trade proclamations on pharmaceuticals and aluminum, steel and copper – CBP updates court on IEEPA duty refund process.

A review of the week's major US international tax-related news. In this edition:  Congress reviewing second US budget reconciliation bill – Possible movement in US Senate's stalled crypto bill – IRS requesting recommendations for 2026-27 Priority Guidance Plan – IRS reportedly considering extending PFIC/CFC overlap rule to new classifications of foreign companies.

A review of the week's major US international tax-related news. In this edition:  US Treasury official discusses Pillar One – OECD official reviews upcoming Pillar Two guidance – IRS extends temporary relief for identifying digital assets – IRS guidance on Section 871(m) dividend equivalent amounts expected mid-year – US Treasury Secretary no longer acting IRS Commissioner, but duties remain.

A review of the week's major US international tax-related news. In this edition:  US Treasury unlikely to issue 'Green Book' with FY'27 Budget – Congressional Republicans debate budget reconciliation legislation option – US official discusses Pillar One and coming OECD Pillar Two guidance – USTR begins 76 Section 301 investigations of US trading partners – US Border Customs describes IEEPA refund claims.

A review of the week's major US international tax-related news. In this edition:  IRS proposes removing final regs on p'ship related-party basis adjustment transactions – Alternative process proposed for digital asset brokers electronic statements – IRS may waive 2025 electronic filing requirement for US and foreign withholding agents – Treasury Secretary says 10%global tariffs will increase to 15% – US Customs and Border Protection outlines possible tariff refund and liquidation mechanics – Federal Circuit rejects tariff refund delay.

A review of the week's major US international tax-related news. In this edition:  President Trump delivers State of the Union address to Congress – OBBBA international tax proposed regs coming mid-year – IRS issues guidance on FX gain or loss – New IRS proposed regs on foreign governments' US investment income will not be applied retroactively – US wants OECD guidance on Pillar Two side-by-side agreement – Trump Administration responds to US Supreme Court's tariff decision.

A review of the week's major US international tax-related news. In this edition:  US Supreme Court strikes down IEEPA tariffs – BEPS two-Pillar solution no longer exists, according to a Treasury official;  Treasury exploring ways to reach an appropriate agreement on the digital economy – President Trump to deliver State of the Union address – IRS issues possible final tranche of additional interim CAMT guidance – OECD releases FAQs on BEPS Pillar One Amount B – US and North Macedonia issue joint statement on "Framework for an Agreement on Reciprocal Trade."

A review of the week's major US international tax-related news. In this edition:  IRS issues guidance on foreign entity restrictions for certain energy credits – Senate fails to pass resolution blocking CAMT partnership notice – US, Taiwan sign trade agreement – White House issues trade EOs on India and Iran.

A review of the week's major US international tax-related news. In this edition:  US partial government shutdown ends – President Trump's State of the Union address set for 24 February – US-Spain CAA on tax treaty arbitration released – President Trump announces India tariff reduction – US moving forward with critical minerals trade zone, supply chain resilience.

A review of the week's major US international tax-related news. In this edition:  US Senate reaches tentative bipartisan funding agreement – President Trump confirms  plans for FY'27 budget – US-EU trade deal back on track – OECD hosted public consultation on global mobility – Next round of UN Framework Convention talks begin 2 February 2026.

A review of the week's major US international tax-related news. In this edition:  US Congress finalizing FY'26 spending bills – Second budget reconciliation bill possible, but uncertain – US, Taiwan complete trade deal.

A review of the week's major US international tax-related news. In this edition:  US Congress making progress on FY26 spending bills – House Republicans eye second budget reconciliation bill – Treasury official says final CAMT notice expected soon – Additional transition guidance on cryptocurrency tax reporting and staking possible – IRS issues guidance for PFICs seeking QEF election – OECD officials offer Pillar Two update – US issues trade proclamations on semiconductors and critical minerals.

A review of the week's major US international tax-related news. In this edition:  OECD releases 'Side-by-Side' Pillar Two global minimum tax agreement – US Congress returns to unfinished business – US Treasury to modify final Section 987 FX regulations – US Supreme Court expected to rule on Trump tariff cases.

A review of the week's major US international tax-related news. In this edition:  US Congress recesses until January – Bipartisan House discussion draft on taxation of digital assets released – US imposes phased-in tariffs on China's semiconductors, related products – USTR modifies tariff agreement with Switzerland – US Supreme Court opinion on President's tariff authority expected.

A review of the week's major US international tax-related news. In this edition: US Congress recesses with no action on ACA credit, other legislation – US optimistic on BEPS Pillar Two global minimum tax side-by-side deal – IRS releases final regulations on determining and reporting qualified derivative payments on securities lending transactions – USTR testifies in Congress on USMCA – USTR warns EU over DSTs.

A review of the week's major US international tax-related news. In this edition:  US Senate fails to advance ACA bills – President Trump says second budget reconciliation bill unnecessary – IRS issues guidance on taxing US investment income of foreign governments – US government considering changes to final FX regulations; releases draft forms – US optimistic for Pillar Two global minimum tax side-by-side deal.

A review of the week's major US international tax-related news. In this edition:  US House subcommittee holds international hearing – Congress will not have a draft crypto-asset legislative framework by year-end – IRS releases 3 OBBBA international tax notices – Cyprus addresses US-Cyprus agreement for exchange of CbC reports – OECD issues CARF report.

A review of the week's major US international tax-related news. In this edition:  IRS addresses OBBBA's repeal of "one-month deferral election" in Code Section 898(c)(2) – Digital asset owners and brokers have new 2025 US information reporting obligations – BEPS 2.0 project update.

A review of the week's major US international tax-related news. In this edition:  Year-end US legislation uncertain – IRS releases final regulations on stock buyback excise tax – Treasury official says OBBBA international guidance coming soon – IRS issues draft instructions for digital transaction filings – US announces new trade frameworks – OECD updates Model Tax Treaty.

A review of the week's major US international tax-related news. In this edition:  US federal government reopens with new CR agreement – Senate committee releases discussion draft legislation on crypto assets market structure – IRS creates safe harbor for investment and grantor trusts to stake their digital assets.

A review of the week's major US international tax-related news. In this edition:  US government shutdown continues amid talks – IRS releases FAQs on digital asset transaction reporting by brokers – President Trump signs two EOs on trade with China – US Supreme Court holds oral arguments in critical tariff case – OECD releases MAP and APA stats on 'Tax Certainty Day."

A review of the week's major US international tax-related news. In this edition:  US government shutdown continues, pressure building – Treasury on track to release OBBBA international guidance by year-end – Congressional leaders warn of retaliatory action if France passes DST legislation – US announces trade Framework Agreements with Malaysia, Cambodia, Thailand and Vietnam.

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.