14 March 2025

Report on recent US international tax developments - 14 March 2025

Congressional Republicans in the House and Senate appear to be coalescing around the prospect of a single budget reconciliation bill centered around extending expiring Tax Cuts and Jobs Act provisions, instead of two separate reconciliation bills. Senate Finance Committee Chairman Mike Crapo (R-ID) said on 12 March that the debate over whether there will be one large budget reconciliation bill or two bills — divided among an initial border security, energy and defense bill and a later tax bill — is over and there will be one reconciliation bill. Among other things, the Finance Committee Chairman was quoted as saying the bill would restore and make permanent research and development expensing and bonus depreciation, as well as a more generous net-interest deduction. He also said the final bill must include President Trump's priorities.

A Senate budget resolution will not be brought to the floor until sometime after Congress returns from next week's recess. The House passed their budget resolution on 25 February. Both the House and Senate need to pass an identical budget resolution to unlock the budget reconciliation process, which would allow the legislation to pass the Senate with a simple majority.

On the House side, the Ways and Means Committee this week began the process of developing a budget reconciliation bill headlined by extensions of the TCJA. While House Republican leaders want a tax bill completed by Memorial Day (i.e., 26 May 2025), some Senate members believe that, given the complexity, final passage of budget reconciliation legislation by the August recess may be more realistic.

Ahead of the expiration of federal government funding on 14 March, the House on 11 March approved a mostly clean continuing resolution (CR) to fund the government through the end of the fiscal year, which ends on 30 September. Senate Minority Leader Chuck Schumer (D-NY) surprised many by saying he would support the House-passed CR to fund the government, significantly increasing the odds that there will be the requisite Democratic votes to approve the measure in the Senate today (14 March).

The House on 11 March joined the Senate in voting to repeal a Biden-era regulation (TD 10021) requiring some cryptocurrency platforms to report their customers' transactions to the Internal Revenue Service, starting with tax year 2027. The Senate approved the resolution on 4 March. The resolution was offered under the Congressional Review Act (CRA), which allows the repeal of agency regulations if the resolution is acted upon within a certain time frame of the rule's publication in the Federal Register. This action represented the first time Congress has eliminated a tax rule using the CRA.

The repealed final regulations governed the reporting of sales of digital assets through decentralized platforms, commonly known as "DeFi," imposing the obligation to report on Form 1099-DA. The regulations were officially published in the Federal Register on 30 December 2024.

The Trump Administration has selected Rebecca Burch to be Deputy Assistant Secretary for International Tax Affairs at the Treasury Department. Burch, currently with Washington Council Ernst & Young, will among other duties, serve as the top US negotiator on the OECD BEPS 2.0 project.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-0693