The US Congress returns from a two-week recess the week of 28 April, beginning the major push to draft a budget reconciliation bill that will extend Tax Cuts and Jobs Act provisions that expire at the end of 2025, among other measures. Besides taxation, the legislation is also expected to address defense, energy, border security and other areas.

In addition to drafting the actual tax provisions, congressional Republicans will also have to consider the reconciliation package's impact on the deficit, revenue offsets and whether the tax measures will be temporary or permanent, among other considerations. House leadership has indicated they would like to have a bill on President Trump's desk for signature by Memorial Day (i.e., 26 May).

Treasury announced that Treasury Deputy Secretary Michael Faulkender will now also assume the role of acting IRS Commissioner. Faulkender was confirmed by the Senate for his Treasury role in late March. President Trump's nominee to become IRS Commissioner, former Missouri Rep. Billy Long (R), is still awaiting his Senate confirmation.

The Treasury is actively discussing with countries how to ensure that the US global intangible low-taxed income (GILTI) regime is recognized and coexists with the OECD Base Erosion and Profit Shifting (BEPS) 2.0 Pillar Two rules, according to a senior Treasury official. "GILTI's been in place for eight years. It was in place before Pillar Two; it's in place today and will continue to be in place," the official said, adding that it would be challenging for companies to be subject to multiple regimes.

The Treasury official added, "This is the viable path to preserve gains within the two global minimum tax systems. … It preserves tax sovereignty, limits disputes, and allows a conversation in a multi-country forum."

The OECD/G20 Inclusive Framework on BEPS — including the US — issued a statement on 11 April, following its meeting in Cape Town, South Africa. The statement described discussions as productive, including those on the original BEPS project and the BEPS 2.0 project. A Global Tax Alert has details.

The United States Trade Representative (USTR) on 17 April announced significant actions in its year-long Section 301 Investigation regarding China's alleged targeting of the maritime, logistics and shipbuilding sectors for dominance. The related Notice of Action and Proposed Action, published on 17 April, outlines two primary categories of proposed actions: (1) fees on maritime transport services and (2) additional duties on certain cargo-handling equipment.

The USTR initiated a Section 301 investigation in April 2024 in response to concerns regarding China's perceived practices aimed at dominating the maritime, logistics and shipbuilding sectors. A Global Tax Alert provides details.