A weekly summary of the top weekly tax news, trends
and developments in the Americas

     This week's tax news from the Americas

• United States issues Executive Orders imposing additional tariffs on Canada, Mexico and China
  On 3 February 2025, the United States postponed additional tariffs on Canada and Mexico, which were scheduled to go into effect on 4 February 2025. Under the Executive Orders previously signed by President Trump, a 25% additional tariff on imports from Canada (10% on energy resources) and Mexico would have applied. An additional tariff of 10% on Chinese-origin went into effect on 4 February 2025.

• United States | Proposed BEAT regulations would provide favorable guidance on qualified derivative payments in securities lending transactions
  In proposed regulations (REG-107895-24; the proposed regulations) released 10 January 2025, under IRC Section 59A, the IRS and Treasury Department outlined how to determine and report qualified derivative payments on securities lending transactions. The proposed regulations also would exclude mark-to-market gain or loss on a securities loan from "base erosion payments" and provide an alternative method to determine the recipient of a substitute payment on a securities loan.

• Canadian government announces deferred implementation date for proposed change to inclusion rate for capital gains
  On 31 January 2025, Canada's Minister of Finance and Intergovernmental Affairs announced the deferral of the effective date for the proposed change to the inclusion rate for capital gains. Specifically, the federal government intends to introduce legislation to defer from 25 June 2024 to 1 January 2026 the date on which the inclusion rate would increase from one-half to two-thirds on (1) capital gains exceeding CA$250k annually for individuals and (2) all capital gains realized by corporations and most types of trusts.

• Bermuda releases public consultation for CIT enforcement provisions
  On 31 January 2025, the Government of Bermuda began a second public consultation (Second Public Consultation) on the administrative provisions of the corporate income tax (CIT). The Second Public Consultation primarily addresses enforcement provisions associated with Bermuda's recently enacted CIT. The three-week consultation period runs from 31 January to 21 February 2025.

• Switzerland and United States sign new Competent Authority Arrangement with implications for US 81-100 group trusts
  Switzerland and the United States signed a new Competent Authority Arrangement (CAA) regarding certain US and Swiss pension and other retirement arrangements' eligibility for treaty benefits under the income tax treaty between the two countries. While the new CAA retains most of the wording in the previous CAA, a new section introduces the procedure for US 81-100 group trusts claiming treaty benefits from Switzerland. The new section details, in particular, the information that an 81-100 group trust should include on its participants when submitting its reclaim application.

      This week's newsletters

• Report on recent US international tax developments - 7 February 2025
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.
• Tax Matters @ EY for February 2025
  Our monthly helps you get up to date on recent tax news, case developments, publications and more.

      Upcoming EY webcasts

• 11 February: What India’s 2025-26 Budget could mean for its economy
• 18 February: What the Trump administration means for business leaders in 2025
• 19 February: International tax talk quarterly series with the EY Global Tax Desk Network - February 2025
• 21 February: Tax in a time of transition

A calendar of all upcoming EY webcasts is available.

      Recent EY podcasts

• EY Podcast | Weekly US international cross-border taxation news for week ending 7 February 2025
• EY talks tax | Tax in a time of transition - 24 January 2025
• EY talks tax | Preparing your operating model for 2025’s expected trade shifts - 22 January 2025
• EY talks tax | GenAI for Legal: How to move from proof of concept to production - 21 January 2025

All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts.

      This week's EY Global Tax Alerts

     Americas

• United States | Executive Order announces “Additional Measures to Combat Anti-Semitism” with focus on American college campuses

     Africa

• Kenya Tax Appeal Tribunal rules income earned by registered pension scheme is exempt from income tax
• Mauritius Supreme Court reverses Assessment Review Committee decision to hold 80% of company's interest income was tax-exempt

     Asia

• India releases Union Budget 2025
• Macau promulgates new tax law with rules on transfer pricing, tax agents and limitations periods
• Pakistan amends sales tax rules for implementation of electronic invoicing
• Taiwan proposes draft amendment to extend application period for reclaims under income tax treaties

     Europe

• France publishes the new declaration form for CbCR and Pillar Two notification
• Italian 2025 Budget Law tax measures — a summary

     Middle East

• Israel makes legislative changes affecting private companies
• Saudi Arabia announces 20th wave of Phase 2 e-invoicing integration
• Turkiye amends regulation on utilization of foreign loans

      This week's EY publications

     Banking and capital markets

• Why lenders should invest in home equity offerings/a>
• Treasury central clearing impacts trading documentation
• Four priorities to drive financial institutions’ in 2025

     Economic outlook

• 2025 global economic outlook: momentum and uncertainty

     Energy

• Moving energy consumers from interest to action

     Mining and minerals

• Unlocking value in mining capital projects: the role of digitalT

     Oil and gas

• 3 trends shaping oil, gas and chemicals in 2025
• Unknowns remain in oil, gas, chemicals post US election
• Driving O&G operations value through data foundation strategy
• Building out the AI-assisted energy company
• Scaling AI for maximum impact in oil and gas

     Power and utilities

• Outlook 2025: four themes empowering utilities

     State and Local Tax

• Active state tax legislative session expected in 2025

     Tax

• Why technology and a solid data foundation are key to tax transparency
• Seven ways early adopters are managing pre-populated VAT returns
• Bring tax advisers to the board room to navigate volatility
• Three prominent tax provision trends for 2025

     Technology

• Enterprise software carve-out strategies

     Trade

• Tips for manufacturers to prepare for President Trump's trade policies

Additional resources

Comments. If you have any questions or suggestions about this newsletter, please email Tax News Update Help at: ustaxalertshelp@ey.com.

About Americas Tax Roundup

Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C.
Jennifer Mannetta, writer and editor

Distributed weekly to all Americas Tax personnel.