EY Cross-Border Taxation Alerts

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.