29 September 2025 Americas Tax Roundup | 29 September 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 Border Services Agency releases notice of preliminary determination for certain carbon and alloy steel wire
In a "Statement of reasons" issued 19 September 2025, the Canada Border Services Agency explained its 4 September 2025 preliminary determinations of dumping of certain carbon and alloy steel wire (the subject goods) originating in or exported from: the People's Republic of China; the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei); the Republic of India; the Italian Republic; the Federation of Malaysia; the Portuguese Republic; the Kingdom of Spain; the Kingdom of Thailand; the Republic of Turkiye; and the Socialist Republic of Vietnam. Provisional duties ranging from 3.5% to 138.6% will now apply to imports of the subject goods included in the 4 September 2025 determination.
- Canada proposes amendments to Global Minimum Tax Act and Income Tax Act
In draft legislation released 15 August 2025, the Canadian Department of Finance proposed changes to Canada’s Global Minimum Tax Act and the Income Tax Act, including (1) introducing the concept of a private investment entity and a related anti-avoidance rule to address issues that can arise from using certain Canadian accounting rules to compute minimum tax liabilities under Pillar Two; (2) amending the rules on reallocating taxes to align with administrative guidance that the Organisation for Economic Co-operation and Development released in June 2024; (3) incorporating revised guidance on the treatment of certain deferred tax assets that arose before the application of the global minimum tax because of certain governmental arrangements or the introduction of a new corporate income tax; and (4) incorporating various changes into the Income Tax Act to ensure further integration of the Pillar Two rules within the broader Canadian domestic tax landscape.
- Bermuda introduces new tax credits
In a Public Consultation on the proposed Tax Credits Act 2025, issued 4 September 2025, the Bermuda Government introduced three new tax credits: a refundable tax credit for regulated insurers to encourage on-island presence through jobs, training and local expenditure; a refundable community development tax credit to encourage charitable giving by businesses; and a utilities infrastructure tax credit to support investment in infrastructure for electricity generation and distribution, digital communications and fuel distribution.
- United States | IRS GLAM concludes that branch profits tax relief is available under treaty for business profits earned by reverse foreign hybrid
In a welcome development, the IRS Office of the Chief Counsel addressed, in a generic legal advice memorandum (AM 2025-002 or GLAM, released 19 September 2025), the application of a US income tax treaty to reduce the branch profits tax (BPT) applicable to a "reverse foreign hybrid" (i.e., a foreign entity treated as a corporation for US tax purposes but as fiscally transparent under the laws of its country of organization and its owners' countries). The IRS concluded that the reverse foreign hybrid may qualify for a reduced rate of BPT on the portion of the dividend equivalent amount corresponding to interests held by the owners who are resident in a treaty country and meet certain treaty eligibility requirements.
- US Sixth Circuit affirms that Eaton must comply with IRS summons for employee evaluations
In US v. Eaton Corp., No. 24-3732 (6th Cir. 8 August 2025), the US Court of Appeals for the Sixth Circuit affirmed that Eaton must comply with IRS summonses requesting annual performance evaluations for certain foreign technical employees as part of a transfer pricing audit. The appeals court determined that the district court properly applied the five-factor comity test, favoring disclosure of performance evaluations despite concerns about the European Union's General Data Protection Regulation.
- Canada Revenue Agency announces streamlined Voluntary Disclosures Program
On 10 September 2025, the Canada Revenue Agency (CRA) released Information Circular IC00-1R7, Voluntary Disclosures Program, and GST/HST Memorandum 16-5-1, Voluntary Disclosures Program (Applications Received On or After October 1, 2025), which overhaul the Voluntary Disclosures Program (VDP) effective 1 October 2025. The CRA's new VDP policy replaces the 2018 framework, as outlined in IC00-1R6, Voluntary Disclosures Program, and GST/HST Memorandum 16-5, Voluntary Disclosures Program, by relaxing the "voluntary" requirement, introducing a two-tier relief model and clarifying the CRA's documentation expectations.
- OECD releases outcomes of eighth peer review on BEPS Action 13 on country-by-country reporting
On 23 September 2023, the OECD published the compilation of the reports from the eighth annual peer review (the Compilation) of the minimum standard for Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) of the Base Erosion and Profit Shifting (BEPS) project. The Compilation, which covers 142 jurisdictions, reflects that jurisdictions' implementation of country-by-country (CbC) reporting (CbCR) is largely consistent with the Action 13 minimum standard. According to the OECD press release, more than 120 jurisdictions have introduced legislation to impose a CbCR obligation on multinational entity (MNE) groups, collectively covering almost all MNE groups with consolidated group revenue at or above the €750m threshold.
| | | | | | | This week's newsletters - The Latest on BEPS and Beyond - 19 September 2025
Our monthly report with brief summaries of the latest activity in the OECD Base Erosion and Profit Shifting (BEPS) project as well as country specific legislative and administrative activity, including global and regional policy trends related to the global focus on BEPS.
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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: 2025-1943 |
