EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: IRS clarifies safe harbor for digital-asset trusts engaged in staking – US officials provide update on coming international tax regulatory guidance – OECD official confirms Brazil and Colombia under consideration for Pillar Two SbS arrangement – USTR announces public consultation for 2027 joint review of USMCA – EY announces former US Treasury and IRS official Ken Kies to join firm.

A review of the week's major US international tax-related news. In this edition: US Congress adjourns for November mid-term elections – Senate Finance Committee member releases comprehensive digital tax bill – OECD releases latest Model Tax Treaty.

A review of the week's major US international tax-related news. In this edition: US Senate to recess after next week, mid-term elections will dictate lame duck priorities – IRS extends transitional relief for dividend equivalents under IRC Section 871(m) through 2028.

A review of the week's major US international tax-related news. In this edition: US House adjourns until post-November mid-term elections – Ways and Means Committee approves digital tax bill – Senate will not address budget reconciliation option until lame-duck session – Ways and Means Committee member introduces international tax bill – OECD releases Global Minimum Tax guidance.

A review of the week's major US international tax-related news. In this edition: US Congress returns for short session before adjourning for November mid-term elections – IRS releases proposed rules to implement OBBBA NCTI and FDDEI expense apportionment provisions – President Trump amends rules for new Canadian tariffs and import prohibitions – OECD releases global information return with side-by-side package.

A review of the week's major US international tax-related news. In this edition: US congressional action on tax legislation uncertain – UN Intergovernmental Negotiating Committee advances negotiations on Framework Convention and early protocols.

A review of the week's major US international tax-related news. In this edition: US House returns 31 August, Senate on 14 September; agenda uncertain – IRS releases proposed regulations on OBBBA rewrite of pro-rata share rules of US shareholder's subpart F inclusions – IRS official says GLAM does not change existing policy on transfer pricing periodic adjustments – US imposes 50% tariffs on Canadian goods after talks collapse.

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations affecting FDDEI determinations – US Tax Court applies anti-abuse rule to deny qualified dividend income and foreign tax credits – President Trump briefly delays Canadian tariffs citing positive negotiations.

A review of the week's major US international tax-related news. In this edition: US Senate adjourns for August recess following release of budget reconciliation resolution – IRS releases proposed FX regulations.

A review of the week's major US international tax-related news. In this edition: US Senate to adjourn for August recess, budget reconciliation (3.0) resolution not expected – Proposed FDDEI and Net CFC Tested Income regulations clear OIRA review – 25 US states file suit against Trump Administration's latest Section 301 tariffs targeting 60 US trading partners.

A review of the week's major US international tax-related news. In this edition: US Senate in session additional week, House adjourned -- IRS releases proposed rules on OBBBA repeal of 'one-month deferral election' – IRS officials address transfer pricing AI concerns, future TP guidance – UN releases draft Framework Convention on Intl Tax Cooperation, two early protocols.

A review of the week's major US international tax-related news. In this edition: US House passes FY27 budget resolution in lead up to budget reconciliation 3.0 – Senate unlikely to complete work on digital asset Clarity Act before August recess – IRS hopes to release updated MAP guidance – OMB set to review IRC Section 250 proposed rules – USTR final action imposes 10% or 12.5% tariffs on 60 US trading partners – US imposes additional 50% tariff on certain Canadian imports.

A review of the week's major US international tax-related news. In this edition: US House Budget Committee approves budget resolution without tax-writing committee instructions – OECD officials offer Pillar Two global minimum tax CIT estimates – OECD reports on MNE responses to global minimum tax – OECD testing risk assessment framework using GMT return data – OECD to present IF with global mobility project proposal – US announces 25% tariffs on Brazilian imports.

A review of the week's major US international tax-related news. In this edition: US Congress to return from recess to possible budget reconciliation 3.0 – Treasury official opposes public CbCR, defends BEPS side-by-side deal – Coming BEPS report to show reduction in tax revenue – USMCA review deadline passes, further talks.

A review of the week's major US international tax-related news. In this edition: US Budget Reconciliation 3.0 still being floated – US and OECD officials offer views on digital taxation and Pillar Two.

A review of the week's major US international tax-related news. In this edition: US congressional Republicans weigh budget reconciliation 3.0 options – US confident of Pillar Two side-by-side agreement, Pillar One is dead – OECD opens public consultation on digital platform tax information exchange – OECD to release copper transfer pricing toolkit.

A review of the week's major US international tax-related news. In this edition: President Trump signs budget reconciliation 2.0 bill, calls for 3.0 – House tax writing committee holds digital tax hearing – US Tax Court rules on cryptocurrency staking awards – OECD IF issues guidance on GloBE information return electronic form.

A review of the week's major US international tax-related news. In this edition: US Senate approves budget reconciliation 2.0 bill – US Treasury Secretary testifies before congressional tax writing committees – House Ways and Means Committee to hold hearing on digital taxation on 9 June – USTR proposes additional ad valorem tariffs on 60 US trading partners – OECD releases public consultation draft on transfer pricing intra-group services.

A review of the week's major US international tax-related news. In this edition: US Congress to return to budget reconciliation legislation after Memorial Day break – JCT issues "Blue Book" on OBBBA – IRS releases proposed Section 892 regs on foreign government income, updating applicability dates – OECD releases updated consolidated commentary to GloBE Model Rules.

A review of the week's major US international tax-related news. In this edition: US Senate moves forward on budget reconciliation 2.0 – Bipartisan digital asset tax bill released – US Treasury official discusses Pillar One and Pillar Two.

A review of the week's major US international tax-related news. In this edition: US Senate moves forward on budget reconciliation legislation – Senate Banking Committee approves crypto market structure bill – US officials offer updates on multiple international tax projects – Federal Circuit temporarily reinstates Trump Administration's 10% global import tariff – OECD to release guidance for upcoming 30 June global minimum tax filing deadlines.

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.