EY Cross-Border Taxation Spotlight for Week ending 21 November 2025

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 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.