Ey Cross-border Taxation Alerts

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.