01 August 2025

Report on recent US international tax developments - 1 August 2025

The US Congress is wrapping up for the August recess, with the House having adjourned on 25 July and the Senate leaving Washington today (1 August). Looking to the fall, there is broad interest in congressional action on additional tax and health provisions later in the year, although exact plans are not clear. House Speaker Mike Johnson (R-LA) confirmed on 23 July that Republicans intend to act on another GOP-only reconciliation bill later this year to address items left out of the "One Big Beautiful Bill Act" (OBBBA). To that end, the House Republican Study Committee (RSC) — which bills itself as the main House GOP conservative caucus — has begun a working group to build out a sequel to the OBBBA.

The chair of the committee, Rep. August Pfluger (R-TX) issued a press release on 25 July, describing the creation of the RSC Reconciliation 2.0 Working Group as the "first organized effort by lawmakers in the House or Senate to chart a concrete policy roadmap for the second reconciliation bill." There is speculation that a potential follow-on bill could address outstanding tax and health issues, Medicaid and other changes cut out of the OBBBA to meet reconciliation rules, OBBBA technical corrections, tax extenders like extension of the Work Opportunity Tax Credit, and possible retirement items.

The Senate Finance Committee this week posted an updated section-by-section summary of the provisions in Title VII of the OBBBA, focusing mainly on tax and health care, which was prepared by Committee Republican staff.

Treasury and the IRS on 29 July released Notice 2025-28 on the application of the corporate alternative minimum tax (CAMT) to applicable corporations with financial statement income (FSI) attributable to investments in partnerships.

The notice provides interim guidance intended to reduce the compliance burdens and costs associated with applying the CAMT to partnerships and CAMT entity partners. The government intends to partially withdraw CAMT proposed regulations and issue new proposed regulations. A Tax Alert on the notice is forthcoming.

There were a number of major US trade developments this week.

President Trump late on 31 July issued an Executive Order announcing a new tariff regime to be implemented beginning 7 August. The so-called "universal" tariff will remain 10% but will only apply to countries with which the United States has a trade surplus. A 15% tariff rate will apply to nations that have a trade surplus with the US. In addition, many countries will face tariff rates higher than 15%, either based on trade framework agreements or because they received a letter from President Trump stating a higher tariff rate will apply. A Global Trade Alert provides details.

The President also signed an Executive Order on 31 July raising the tariffs on Canadian imports not covered by the United States-Mexico-Canada free trade agreement — from 25% to 35% — in effect 2 August. On the same day, the President announced a trade deal with South Korea that calls for 15% tariff rates.

President Trump on 30 July further issued an Executive Order imposing a 40% ad valorem duty on Brazilian-origin imports, effective from 6 August 2025. The new tariff will stack with existing tariffs (excluding Section 232 tariffs), and will not apply to specific exempt products, including civilian aircraft, aluminum, energy products and select agricultural goods. A Global Trade Alert has details.

And earlier in the week, President Trump on 27 July announced a trade deal with the European Union (EU) that would set 15% tariffs. The President was quoted as saying the deal includes the EU purchase of US$750b of American energy, and there are reports a range of goods will see a 0% tariff.

On 30 June, the President signed a Proclamation titled "Adjusting Imports of Copper into the United States," which imposes 50% tariffs, effective 1 August, on imports of semi-finished copper products and copper-intensive derivative products. A Global Trade Alert has details.

The White House on 30 July issued a major report titled Strengthening American Leadership in Digital Financial Technology. The eagerly anticipated digital asset report provides a comprehensive framework that is meant to position the US as a global crypto leader. The report also addresses the taxation of digital assets.

The OECD on 30 July released two XML Schemas and related User Guides addressing reporting and information exchange under the global minimum tax and the Crypto-Asset Reporting Framework (CARF), respectively. The Schemas can be found here: GloBE Information Return (Pillar Two) Status Message XML Schema and updated Crypto-Asset Reporting Framework (CARF) XML Schema.

The OECD also issued updated FAQs on the CARF and the amended Common Reporting Standard (CRS).

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-1642