19 October 2025 This Week in Tax Policy for October 20 The Senate is set to vote again on the House-passed CR (H.R. 5371) at 5:30 p.m. on Monday, October 20. Government shutdown: The focus in Washington remained on the government shutdown, with no resolution in sight and some members suggesting it could continue for a while. Democrats have not relented in their demand for an extension of enhanced Affordable Care Act (ACA) premium tax credits as part of a continuing resolution (CR) to extend government funding, even as the Administration has cut funding to government programs and pursued federal workforce layoffs. Republicans say they won't negotiate on the premium tax credits issue until Democrats vote to reopen the government through the GOP CR that patches funding until November 21. Health subsidies: There has been some movement on the enhanced ACA credits issue. Senate Majority Leader John Thune (R-SD) has more directly offered Democrats a vote on an extension of enhanced Affordable Care Act (ACA) premium tax credits within a specific timeframe, but only after they provide the necessary votes for a continuing resolution (CR) to extend government funding and end the shutdown. "We can guarantee you get a vote by a date certain," Leader Thune said on MSNBC. "At some point, Democrats have to take 'yes' for an answer." Punchbowl News reported Leader Thune as saying he has offered Democrats a two-vote deal: one on opening the government, the other on a separate one-year extension of enhanced premium tax credits. Senate Democratic leader Chuck Schumer (D-NY) told reporters he was unaware of such an offer. Senators such as Jeanne Shaheen (D-NH) had suggested before the shutdown that a promise by Republican leaders to hold a vote on extending ACA subsidies could be enough for some members to back the GOP CR. But she suggested to MSNBC that her thinking has evolved, and that Thune's offer isn't sufficient. "When the shutdown was just starting, we requested that," she said Thursday. "That's been almost three weeks ago, and they wouldn't do it, wouldn't do it, wouldn't do it. And now he has moved but everybody else has moved, too." But there is the sense that there will ultimately be negotiations for legislation on the ACA credits. Politico reported that Republicans are crafting a "menu of options" for eventual negotiations, including income caps, cutoffs for new enrollees, and minimum out-of-pocket premiums. Another report said that Republicans are considering extending the enhanced credits in a potential bipartisan year-end bill with some of their own priorities. "Republicans have been discussing a menu of other options in the health care policy arena, both among themselves and with White House officials," the story said. "Ideas include overhauling the operation of drug intermediaries, known as pharmacy benefit managers; granting Americans additional options around Health Savings Accounts; and allowing more flexible employer-provided health insurance plans." Prospects for year-end tax bill: The reporting on Republican health ideas is consistent with wide speculation about a potential year-end package addressing expiring tax, health and trade items, though it would likely require a bipartisan appropriations bill as the vehicle. The outlook for such a bill is uncertain with the shutdown, as is the question of which issue could be the main driver of a package. If ACA credits aren't extended before then, the health piece would likely provide the most momentum. In the tax area, provisions with bipartisan interest include the remaining tax extenders (i.e., those not included in the "One Big Beautiful Bill Act") — including the Work Opportunity Tax Credit (WOTC), IRC Section 181 100% deduction for film/TV production costs, and the seven-year recovery period for motorsports entertainment complexes — plus US-Taiwan tax relief, and cryptocurrency provisions. An October 14 Daily Tax Report story, "Shutdown Could Dampen Congress' Bipartisan Tax Extender Appetite," said: "Popular support for each extender break individually may be insufficient to overcome that strife, said Ray Beeman, who leads EY's Washington Council practice. Because lawmakers' terms aren't expiring this year, they may feel that waiting until 2026 and extending the breaks retroactively is more attractive, Beeman said. The funding lapse has also fractured the attention of lawmakers and their staff, dimming the prospects of planning a package. 'At least, while there's a shutdown, I just don't think anybody's super focused on' other extenders, Beeman said." There is also broad speculation about Republicans reviving the IRC Section 899 reciprocal tax proposal, which was dropped from the OBBBA. Global tax: The OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 South Africa, October 2025) said regarding Pillar Two of the global tax agreement, "The contours for a potential side-by-side arrangement that addresses concerns is being discussed within the wider Inclusive Framework membership with an aim to expeditiously reach a solution that is acceptable and implementable while maintaining the overall integrity of the global minimum tax framework. In parallel, and in response to stakeholder feedback, the Inclusive Framework continues to work on simplifying compliance with the global minimum tax for MNE Groups operating in jurisdictions with a high effective tax rate." A June 28 G7 statement called for a side-by-side system that would exempt US multinationals from certain of the Pillar Two global minimum tax rules.
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