The US House Ways & Means Tax Subcommittee on 3 December held a hearing on "Promoting Global Competitiveness for American Workers and Businesses." The hearing focused largely on the benefits of Republican tax reform legislation in 2017 and 2025, potential additional international tax law changes and Democratic concerns over the Administration's tariffs policies.

The hearing also included significant discussion on the OECD-led global tax deal, as negotiations continue to reach an international agreement for a side-by-side system that would exempt US multinationals from most Pillar Two global minimum tax rules. The G7 issued a statement in June 2025 calling for a side-by-side system, which has been the subject of ongoing negotiation within the Inclusive Framework.

Ways & Means Committee Chairman Jason Smith (R-MO) said, with respect to the proposed side-by-side system, "I intend to see that June announcement to the finish line." The chairman further said, "We expect to see the technical work that has been done in these negotiations move forward this week." He also renewed his warning that Congress will take action if other nations walk away from the side-by-side agreement.

Chairman Smith at the hearing raised the specter of reviving proposed IRC Section 899, a counter tax measure, if a side-by-side agreement is not reached. Proposed IRC Section 899 was stricken from the "One Big Beautiful Bill Act" (OBBBA) last summer at the request of the Trump Administration following the G7 announcement.

The hearing also saw Ways & Means Tax Subcommittee members Ron Estes (R-KS), Randy Feenstra (R-IA) and Nathaniel Moran (R-TX) talk about the importance of continuing to make further improvements to the US international tax system, highlighting specific proposals during the hearing. Testimony from the subcommittee hearing is available here.

A draft crypto-asset legislative framework will not be released before the end of 2025, according to two lead congressional legislators on the issue. Senate Finance Committee member Steve Daines (R-MT) and House Ways & Means Committee member Max L. Miller (R-OH) this week were quoted as saying "more than likely, it's going to be a priority for next year." The legislators blamed the government shutdown for the delay, despite bipartisan support in Congress to develop a comprehensive and competitive approach to digital asset taxation.

Treasury and the IRS on 4 December released three notices implementing international provisions of the OBBBA. Notice 2025-75 provides guidance on the application of a transition rule applicable to certain dividends paid by a controlled foreign corporation (CFC) before the new pro-rata share rules in IRC Section 951(a)(2)(B) take effect. Notice 2025-77 provides guidance on the application of the treatment of taxes imposed on previously taxed earnings and profits (PTEP) distributions under new IRC Section 960(d)(4). And Notice 2025-78 provides guidance on the treatment, for purposes of IRC Section 250 Foreign-derived Deduction Eligible Income (FDDDEI), of certain transactions occurring after 16 June 2025.

This completes the series of four Notices that was expected on the international tax provisions in the OBBBA before the end of the calendar year. (The government on 25 November released Notice 2025-72, which addresses the OBBBA's repeal of the "one-month deferral election" in IRC Section 898(c)(2).) A corporate alternative minimum tax (CAMT) Notice is still expected before the end of the year, as well as a variety of guidance on other areas of tax. A Tax Alert is pending.

Cyprus's Tax Department on 25 November publicly announced that the bilateral Competent Authority Agreement for the exchange of Country-by-Country reports between Cyprus and the United States, which is still under negotiation, is expected to be effective for reporting financial years (RFYs) beginning on or after 1 January 2025.

A secondary filing mechanism for a Cypriot Constituent Entity (CE) of a multinational enterprise group with a US-tax-resident Ultimate Parent Entity applies for RFYs beginning during calendar year 2024. Cypriot CEs that have already filed notifications in Cyprus for RFYs that began during 2024 must revise those notifications by the end of 2025 to avoid penalties. A Global Tax Alert provides details

The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes recently issued a report that said 75 jurisdictions have made a "political commitment" to implement the Crypto-Asset Reporting Framework (CARF). According to the report, this includes a "general expectation that the CARF is implemented in time to commence exchanges under the CARF from 2027 or 2028." The Global Forum's website includes up-to-date information on the jurisdictions that committed to implement CARF.