11 April 2025 Report on recent US international tax developments - 11 April 2025 The US House on 10 April passed the Senate budget reconciliation resolution, meaning both chambers have now passed the same FY2025 budget resolution. This clears the path for using the reconciliation process to pass a bill to extend Tax Cuts & Jobs Act provisions that expire at the end of 2025. The Senate-passed resolution did not include additional spending cuts but left the House reconciliation instructions unchanged — that is, $2t in deficit reduction as a condition for a full $4.5t in tax cuts, including for the Energy & Commerce Committee to come up with at least $880b in spending cuts. Congressional Republicans now must decide how to achieve the desired level of spending cuts and address the many issues regarding the tax provisions, including what additional proposals to include, how to pay for them, and how relief from the $10,000 state and local tax deduction cap should be accomplished. Given the decision to attempt a single budget reconciliation bill — instead of bifurcating tax and other priorities into two permissible reconciliation bills this year — Congress will also have to address defense, energy, border security and other areas simultaneously. Added to the mix is President Trump's desire to enact his tax proposals, which include no tax on tips, overtime and Social Security benefits, plus cutting taxes on "domestic production and all manufacturing." Congress will begin a two-week recess starting next week, after which it will begin the process of drafting legislation to enact the massive bill. President Trump on 9 April announced a 90-day pause on the additional country-specific tariff rates on countries with which the US has large trade deficits and trade barriers — the same day they took effect — but suggested 10% universal tariffs would remain in effect. The President said the decision was made "based on the fact that more than 75 Countries have called Representatives of the United States, including the Departments of Commerce, Treasury, and the USTR, to negotiate a solution to the subjects being discussed relative to Trade, Trade Barriers, Tariffs, Currency Manipulation, and Non-Monetary Tariffs, and that these Countries have not, at my strong suggestion, retaliated in any way, shape, or form against the United States." There were also US developments with respect to China. President Trump reacted to Chinese countermeasures by increasing US tariffs on China from 34% to 84% and then to 125% in a subsequent announcement. The President further increased the formerly duty-free de minimis treatment for certain goods from Mainland China and Hong Kong. A Global Tax Alert provides details. President Trump on 10 April signed H.J. Res. 25, repealing crypto-reporting final regulations (T.D. 10021) under authority provided by the Congressional Review Act (CRA). The final regulations required some cryptocurrency platforms to report their customers' transactions to the IRS, starting with tax year 2027. The CRA allows the repeal of agency regulations if the resolution is acted upon within a certain timeframe following the rule's publication in the Federal Register. This action was 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, Digital Asset Proceeds from Broker Transactions. The regulations were officially published in the Federal Register on 30 December 2024. The IRS this week issued Notice 2025-19, inviting the public to recommend topics to be added to the 2025–2026 Priority Guidance Plan. The annual plan identifies and prioritizes tax issues that should be addressed in IRS guidance. The 2025–2026 plan will establish the government's tax priorities over the period 1 July 2025 through 30 June 2026. Submissions must be received by 30 May to be considered for next year's plan.
Document ID: 2025-0873 | ||||