EY Cross-Border Taxation Alerts

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.