Republicans in Congress reportedly plan to move early in 2025 on a budget reconciliation bill focused on extensions of the expiring provisions of the Tax Cuts and Jobs Act (TCJA). House Majority Leader Steve Scalise (R-LA) said, during a 19 November press conference, that he “assembled all of the committee chairs last week to go through what we will be doing in budget reconciliation,” with the expectation of a “very aggressive first 100-day agenda.”

Other Republican leaders are confirming that two separate budget reconciliation bills will be available for enacting GOP-only proposals with a simple majority vote in the Senate in the next Congress. Jodey Arrington (R-TX), the Chairman of the House Budget Committee, said “We’ll have two bites at the reconciliation apple in the next calendar year.” Congress failed to pass a budget for FY2025, and that resolution can provide for one reconciliation bill, with another then available for FY2026.

The opportunity for two reconciliation bills provides congressional Republicans with various options to enact tax legislation. One proposal reportedly under consideration would be to pass an initial bill that would address TCJA expiring provisions, with a second reconciliation bill later in 2025 that would address President-elect Trump’s various campaign proposals, including the 15% tax rate for domestic manufacturing.

Congress is set to begin the Thanksgiving recess and will return in December to continue the lame-duck session with a preholiday deadline for a government funding bill.

The OECD on 15 November held its sixth annual OECD Tax Certainty Day, during which it released the 2023 statistics on Mutual Agreement Procedures (MAP) and, for the first time, also released Advance Pricing Arrangements (APA) statistics.

The OECD reported that MAP case inventory for new cases (post-2016) have decreased for the first time, with last year (2023) seeing a reduction in inventory of approximately 16% for new transfer pricing cases and an increase of 2.8% for new "other" cases, as compared with 2022. Overall MAP inventories decreased by 3.8%. The OECD indicated that 74% of total MAP cases closed and fully resolved the issue under dispute in 2023.

Releasing APA statistics for the first time, the OECD reported that in 2023, more than 1,100 APAs were requested and more than 800 APAs were granted; only 15 were rejected when initiated and 100 closed for other reasons. A Global Tax Alert provides details.