28 March 2025

Report on recent US international tax developments - 28 March 2025

The timeline for steps to develop a budget reconciliation tax bill that congressional Republicans want to pass is becoming clearer. Congressional Republican leaders in each chamber, tax committee chairmen, Treasury Secretary Scott Bessent, and National Economic Council Director Kevin Hassett met on 25 March to discuss the budget reconciliation process and the shape of a future tax bill to extend provisions in the Tax Cuts and Jobs Act. The meeting reportedly ended on an upbeat note, with the Treasury Secretary quoted as saying he was confident a "swift timeframe is achievable."

Senate Majority Leader John Thune (R-SD) said on 26 March that he wants the Senate to vote on a compromise budget resolution as soon as the week of 31 March. An updated WCEY Alert, Pathways to budget reconciliation in 2025, lays out the issues and compromises that may need to be made to pass a budget reconciliation bill.

President Trump in a 26 March White House Proclamation announced 25% additional tariffs on imports of automobiles and automobile parts to protect the national security of the United States. The 25% ad valorem tariff is in addition to any other duties, fees, exactions, and charges applicable to the automobiles and automobile parts. Tariffs on automobiles will be effective on 3 April 2025 and tariffs on automobile parts will be effective no later than 3 May 2025. The process is evolving, and more details on the covered automobile products will be published in the Federal Register. A Tax Alert provides details.

Rep. Ron Estes (R-KS) and every Republican member of the House Ways and Means Committee on 27 March reintroduced the Unfair Tax Prevention Act (H.R. 2423) to ensure that if a country moves forward with an Undertaxed Profits Rule (UTPR) under OECD BEPS Pillar Two, the US will impose a reciprocal tax measure. The bill strengthens anti-avoidance rules in the base erosion and anti-abuse tax (BEAT), revokes the ability of foreign-owned extraterritorial tax regime entities to disregard certain service payments and payments subject to withholding taxes, and treats 50% of cost of goods sold as a base erosion tax benefit.

The IRS issued Announcement 2025-13 on 26 March, releasing the 26th annual IRS advance pricing agreement report covering the 2024 calendar year. According to the Advance Pricing and Mutual Agreement Program (APMA), the IRS finalized 142 APAs in 2024, a reduction from 156 APAs in 2023. A Tax Alert provides details.

The IRS in Announcement 2025-08 reported that US and Swiss competent authorities entered into a mutual agreement to extend the benefits of Article 10 (Dividends) of the US-Switzerland income tax treaty, in relation to certain US and Swiss pension or other retirement arrangements. The latest competent authority agreement supersedes one signed in May 2021.

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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: 2025-0780