EY Cross-Border Taxation Spotlight for Week ending 24 July 2026

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.