EY Cross-Border Taxation Spotlight for Week ending 31 October 2025

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 securities lending and sale-repurchase transactions – President Trump ends trade talks with Canada – OECD issues new TP country profiles.

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 Administration announces new tariff plans.

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 – President Trump signs EO on trade and security agreements – OECD releases report on revised BEPS Action 5 transparency framework.

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 President Trump's tariff policy case, oral arguments week of 3 November.

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%.