16 June 2025 Americas Tax Roundup | 16 June 2025 | | A weekly summary of the top weekly tax news, trends and developments in the Americas | | | | | | | | | | This week's tax news from the Americas - Canada's DST may trigger proposed US IRC Section 899
The One Big, Beautiful Bill Act (OBBBA, H.R. 1), passed by the United States (US) House of Representatives on 22 May 2025, could significantly affect certain Canadian businesses. Canada's prior enactment of a digital services tax would cause Canada to effectively be classified as a "discriminatory foreign country" under proposed IRC Section 899. As a result, Canadian entities would be subject to higher income and withholding tax rates on US-source income. The increased tax rates would apply to various types of income, including dividends, royalties and capital gains, significantly impacting Canadian individuals, corporations and trusts with US investments.
- Canada Border Services Agency updates customs notice for surtax remission
On 20 May 2025, the Canada Border Services Agency released a revised version of Customs Notice 25-19, United States Surtax Remission Order (2025)(Customs Notice). This notice, which was originally published on 17 April 2025, contains new information about the application of the United States Surtax Remission Order (2025) (Remission Order). The Remission Order provides a six-month relief period for surtaxes on certain goods imported from the United States, including goods used to support public health, health care, public safety and national security objectives, as well as goods imported for use in Canadian manufacturing, processing, and food and beverage packaging. The Customs Notice contains guidance on the eligibility of goods for remission under the Remission Order.
- Bermuda releases first public consultation for CIT technical amendments
On 29 May 2025, the Government of Bermuda began a first public consultation (First Public Consultation) concerning a first set of proposed technical amendments to the Corporate Income Tax Act 2023 (CIT Act). The First Public Consultation primarily intends to clarify certain provisions, better align the CIT Act with the Global Anti-Base Erosion rules as appropriate and make come clerical and administrative corrections. The three-week consultation period runs from 29 May to 19 June 2025.
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Comments. If you have any questions or suggestions about this newsletter, please email Tax News Update Help at: ustaxalertshelp@ey.com. | | | | | 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. | | |
Document ID: 2025-1247 |