The Trump Administration is replacing newly installed IRS Commissioner Billy Long less than two months into his tenure. The White House announced that Treasury Secretary Scott Bessent will be acting IRS Commissioner, taking on both roles. Commissioner Long indicated he will be the next US ambassador to Iceland.

Treasury Assistant Secretary for Tax Policy Kenneth Kies also holds two major positions in the Administration, as IRS Chief Counsel in addition to his Treasury post.

President Trump on 11 August issued an Executive Order (EO) titled, "Further Modifying Reciprocal Tariff Rates to Reflect Ongoing Discussions with the People's Republic of China," extending the suspension of heightened tariffs on Chinese imports until 10 November 2025. The current 10% reciprocal tariff rate will remain in force during the suspension period. Other US tariff measures regarding China will remain in effect.

The White House Fact Sheet on the latest EO describes the trade discussions with China as having been constructive.

The High Court of Australia this week issued a decision in PepsiCo v Commissioner of Taxation[2025] HCA 30, a royalty withholding tax and diverted profits tax (DPT) embedded royalties case. The Court ruled for PepsiCo in the closely watched decision.

The decision has potentially significant implications for the Australian Taxation Office's (ATO's) interpretation of royalties. The ATO has issued a statement indicating they are considering the decision and any broader impact it may have on the reasoning set out in draft TR 2024/D1 (Income tax: royalties — character of payments in respect of software and intellectual property rights). It is also expected that the ATO's draft practical compliance guideline PCG 2025/D4 (Low-risk payments relating to software arrangements — ATO compliance approach) will be amended to reflect the decision when it is published as final. A Global Tax Alert provides details.

The Intergovernmental Negotiating Committee to develop a United Nations (UN) Framework Convention on International Tax Cooperation wrapped up two substantive sessions in mid-August. The committee discussed the taxation of cross-border services income and dispute prevention and resolution, among other topics.

The Intergovernmental Negotiating Committee is scheduled to meet three times each year in 2025, 2026 and 2027, with the expectation of submitting the final text of the Framework Convention and two early protocols to the General Assembly for consideration in 2027.

On 27 June 2025, the Intergovernmental Negotiating Committee released three draft issues notes related to its three workstreams. (A Global Tax Alert on the draft notes is here.) The notes and input received from stakeholders and member countries were considered during the August sessions. The three workstreams aim to develop the draft text of the UN Framework Convention, the early protocol on taxation of income derived from the provision of cross-border services and the early protocol on prevention and resolution of tax disputes.