President Trump's signing into law the massive budget reconciliation bill (H.R. 1 — "known as the "One Big Beautiful Bill" (OBBA)) on 4 July makes major changes to many areas of US international tax law that will affect both inbound and outbound taxpayers. The substantive changes will require immediate review to determine how the new provisions will affect current structures, operations and future plans, including what action — if any — should be taken now. An ITTS Alert provides details on the enacted international provisions.

Now that the bill has been enacted, expect a renewed focus on trade given ongoing trade negotiations and tariff deadlines.

Cryptocurrency was a major focus in Congress this week.

First, the House on 17 July passed the GENIUS Act, a landmark Senate bill (S. 1582) regulating a type of cryptocurrency called stablecoins, which are designed to match the value of another stable asset such as the US dollar. The coins are often used to facilitate trades of other, more volatile digital assets such as Bitcoin. The House this week also passed the CLARITY Act crypto market structure bill and finished by passing H.R. 1919, which would prohibit the Federal Reserve System from studying or issuing a central bank digital currency.

President Trump is expected to sign the GENIUS Act today (18 July), while House backers hope that the House vote will propel the Senate to take up the CLARITY Act.

The House Ways and Means Oversight Subcommittee also held a hearing on 16 July, titled "Making America the Crypto Capital of the World: Ensuring Digital Asset Policy Built for the 21st Century." Two main issues were discussed at the hearing:

1. Digital assets are treated as property; any transfer or exchange can trigger taxable income; and the industry is pushing for a de minimis rule to exempt transactions under a threshold from taxation and reporting requirements.
2. The industry wants staking, or the validation of transactions and issuing of rewards that currently must be included in income when the taxpayer gains control, to be treated like other created property — taxed at the time of sale, not at the time of creation.

These issues are addressed in a bill (S. 2207) introduced on 30 June by Senator Cynthia Lummis (R-WY). Sen. Lummis's press release on the bill is here.

OECD officials this week provided insights across a number of tax areas currently under consideration. The head of the transfer pricing unit at the OECD Centre for Tax Policy and Administration said the transfer pricing guidelines will be adapted to address new realities regarding remote work, global mobility and artificial intelligence. There will also be efforts to standardize common understanding of certain transfer pricing terminology for purposes of uniform interpretation. The official pointed to the arm's-length range and the use of the median as areas in which there is no universal agreement. Another area that may require review is business segmentation in the context of mutual agreement procedures, when one jurisdiction adjusts a controlled transaction.

Another OECD official this week said that work is planned on an advance pricing agreement-type system that would address non-transfer pricing issues to provide better tax certainty — for example, in terms of permanent establishments. Other areas reportedly being reviewed include updating the 2007 Manual on Effective Mutual Agreement Procedures (MEMAP) and addressing whether the existing international assurance program should be adapted to provide certainty under the BEPS Pillar Two global minimum tax rules.

On 27 June, the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation released three draft issues notes on its workstreams: Workstream I on the framework convention, Workstream II on the early protocol on taxation of services, and Workstream III on the early protocol on tax dispute prevention and resolution. A Global Tax Alert provides details.