EY Cross-Border Taxation Alerts

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...

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...

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 secu...

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...

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...

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 Presi...

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...

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...

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.