| | This week's tax news from the Americas - US House approves tax reconciliation bill, with minor rate changes in international tax provisions
On 22 May 2025, the US House approved the budget reconciliation bill (the House Bill), after incorporating a manager's amendment. Compared to the bill approved by the House Ways and Means Committee on 13 May 2025, the House Bill would slightly modify the rates for global-intangible-low-taxed-income, foreign-derived-intangible-income, and the base-erosion-anti-abuse-tax, but would not change the rest of the international tax proposals, including newly proposed IRC Section 899 (which is intended to target "unfair foreign taxes"). The small adjustments to the international rates may be an attempt to smooth passage of the bill given the Senate's reconciliation process. The international provisions, however, may change, potentially significantly, as the House Bill advances to the Senate.
- US IRS reissues interim guidance on Advance Pricing Agreement submissions
The US IRS has reissued the Memorandum for Treaty and Transfer Pricing Operations Employees (memo), which listed previously internal procedures for Advance Pricing Agreement (APA) prefiling meeting requests and the review and acceptance of APA submissions. The IRS reissued the memo because the original one expired on 25 April 2025. The reissued memo has an expiration date of 22 October 2025, at which point it is anticipated that the guidance will be incorporated into Internal Revenue Manual 4.60.3. The memo implemented a rigorous screening process whereby the Advance Pricing and Mutual Agreement team (along with other Treaty and Transfer Pricing Operations personnel) may shift taxpayers from the APA process to alternative workstreams.
- Brazilian Government introduces changes to regulations dealing with the taxation of financial operations
On 22 May 2025, the Brazilian Federal Government published Decree 12.466/2025, significantly increasing tax rates on credit transactions (IOF-credit) and certain foreign exchange transactions (IOF-FX), effective from 23 May 2025. The Government also issued Decree 12.467/2025 on 23 May 2025, revoking one of the changes contemplated by Decree 12.466/2025 involving investment funds abroad and companies that make funds available abroad for investment purposes.
- Canada | Ontario budget 2025-26
On 15 May 2025, Ontario Finance Minister Peter Bethlenfalvy tabled the province's fiscal 2025-26 budget. The budget contains some tax measures but contains no new taxes and no tax increases. The minister anticipates a deficit of CA$14.6b for 2025-26 and CA$7.8b for 2026-27, before returning to a surplus position of CA$0.2b in 2027-28.
- Costa Rica | New virtual tax administration platform to launch in August 2025
The Ministry of Finance has released updates on the progress, key changes and implementation timelines for the new virtual platform TRIBU-CR, which will replace existing platforms (including TRAVI, ATV, and EDDI-7) starting in August 2025. Although these changes are still in draft, it is possible to anticipate several of the main features based on draft resolutions currently under public consultation and recent statements made by the Tax Administration officials in media and public events.
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| | 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. | |
