Federal Tax | State & Local Tax | International Tax
Human Capital & Workforce, Individual and Indirect Tax This year in review lists all EY Tax Alerts concerning significant U.S. international tax developments, as well as key OECD BEPS developments, during 2025. |
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| Key U.S. international tax developments, 2025 |
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| 12.16.2025 | US Court of International Trade clarifies refund pathway for IEEPA tariffs, denies preliminary injunction in IEEPA-related refund case (2025-2530) |
| 12.11.2025 | IRS memorandum confirms sourcing of borrow fees for foreign partnership as recipient's residence (2025-2475) |
| 12.10.2025 | FinCEN continues to extend certain signature authority reporting (FBAR, Form 114) (2025-2466) |
| 12.03.2025 | Ways and Means Subpanel holds global tax hearing (2025-2414) |
| 12.01.2025 | Cyprus tax authorities issue clarification note regarding bilateral agreement with United States (2025-2388) |
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| 11.17.2025 | US announces new trade frameworks and expanded agricultural tariff exclusions (2025-2308) |
| 11.06.2025 | OECD's 2024 Mutual Agreement Procedure statistics show increase in US cases closed and new cases filed (2025-2239) |
| 11.05.2025 | Treasury and IRS propose removing domestic corporation look-through rule for domestically controlled QIEs (2025-2230) |
| 11.04.2025 | US President announces new trade and economic deal with China and commitments to Republic of Korea (2025-2220) |
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| 10.30.2025 | Forthcoming proposed regulations would source borrow fees paid with respect to securities lending and sale-repurchase transactions to residence of the recipient (2025-2195) |
| 10.27.2025 | District court finds pharmaceutical company entitled to refund of taxes, upholds company's argument on economic substance doctrine (2025-2161) |
| 10.23.2025 | IRS issues additional interim guidance that adds flexibility on relying on the corporate alternative minimum tax guidance (2025-2143) |
| 10.01.2025 | US expands export controls to include 50% 'Affiliates Rule' for restricted parties (2025-1984) |
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| 09.30.2025 | US President announces new Section 232 tariffs on imports of timber, lumber and their derivative products (2025-1963) |
| 09.26.2025 | US Trade developments include announced new tariffs on pharmaceuticals, Section 232 investigations into imports including robotics, industrial machinery, PPE and medical equipment (2025-1948) |
| 09.25.2025 | United States | IRS GLAM concludes that branch profits tax relief is available under treaty for business profits earned by reverse foreign hybrid (2025-1935) |
| 09.25.2025 | US Sixth Circuit affirms that Eaton must comply with IRS summons for employee evaluations (2025-1934) |
| 09.19.2025 | Canada removing tariffs on certain US goods; Canadian business support measures announced (2025-1890) |
| 09.18.2025 | US-Japan Agreement updated and public comment period open for Section 301 extensions (2025-1882) |
| 09.16.2025 | USTR launches USMCA review public process (2025-1870) |
| 09.15.2025 | US Executive Order modifies scope of certain tariffs and establishes procedures for implementing trade and security agreements (2025-1863) |
| 09.12.2025 | Eighth Circuit sends Medtronic case back to the US Tax Court for further analysis (2025-1852) |
| 09.10.2025 | US Supreme Court will hear oral arguments in tariff case in early November 2025; opening briefs due soon (2025-1832) |
| 09.08.2025 | US President Trump issues Executive Order implementing terms of United States-Japan Agreement (2025-1803) |
| 09.03.2025 | USTR extends product exclusions subject to Section 301 tariffs through 29 November 2025 (2025-1786) |
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| 08.26.2025 | US Treasury and IRS announce intent to withdraw the DPL rules, modify the DCL rules, and extend DCL transitional relief for Pillar Two Taxes (2025-1756) |
| 08.22.2025 | Treasury and the IRS announce they will relax FIRPTA rules for certain inbound reorganizations of publicly traded corporations (2025-1742) |
| 08.07.2025 | US Department of State introduces visa bond pilot program for certain visa applicants (2025-1666) |
| 08.06.2025 | US imposes additional tariffs on India for buying oil from Russia (2025-1663) |
| 08.01.2025 | US imposes additional tariffs on imports from trading partners (2025-1640) |
| 08.01.2025 | US imposes tariffs on copper products (2025-1634) |
| 08.01.2025 | US suspends duty-free de minimis treatment for low-value shipments (2025-1633) |
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| 07.31.2025 | US imposes additional tariffs on Brazilian-origin goods (2025-1632) |
| 07.29.2025 | International tax changes in final reconciliation legislation may affect privately held businesses and their stakeholders (2025-1613) |
| 07.28.2025 | New law finalizes definition of foreign entities of concern, additional guidance must be issued within 45 days (2025-1608) |
| 07.24.2025 | EY article addresses accounting considerations for key income tax changes in 'One Big Beautiful Bill Act' (2025-1573) |
| 07.21.2025 | US Tax Court finds AbbVie properly deducted merger termination fee as an ordinary loss (2025-1543) |
| 07.17.2025 | United States | Changes to GILTI, FDII and BEAT, among others, included in final reconciliation legislation, but not previously proposed remedy for "unfair foreign taxes" (2025-1510) |
| 07.17.2025 | Several changes in final FY 2025 reconciliation legislation could benefit oil and gas industry (2025-1508) |
| 07.17.2025 | District court allows summons for performance evaluations of technical employees in Eaton case (2025-1507) |
| 07.17.2025 | IRS releases 2025 template for Advance Pricing Agreements (2025-1506) |
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| 06.26.2025 | Secretary Bessent asks Congress to cut Section 899 from OBBBA (2025-1365) |
| 06.23.2025 | United States | Senate Finance Committee version of tax reconciliation bill adds new international proposals, modifies other proposals in House-passed bill (2025-1330) |
| 06.16.2025 | IRS updates revenue procedure on automatic accounting method changes (2025-1273) |
| 06.12.2025 | US Treasury Department and IRS issue new CAMT interim guidance (2025-1244) |
| 06.05.2025 | Canada's DST may trigger proposed US IRC Section 899 (2025-1200) |
| 06.05.2025 | Tax Court rules for first time that income method is valid but reduces IRS's valuation (2025-1196) |
| 06.04.2025 | US increases import tariffs of aluminum and steel (2025-1192) |
| 06.03.2025 | USTR extends certain exclusions from China Section 301 tariffs (2025-1186) |
| 06.02.2025 | United States | Proposed IRC Section 899 would affect certain asset management entities (2025-1172) |
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| 05.30.2025 | Court of International Trade rules tariffs under International Emergency Economic Powers Act unlawful; appeals court temporarily reinstates tariffs as case proceeds (2025-1163) |
| 05.28.2025 | US House approves tax reconciliation bill, with minor rate changes in international tax provisions (2025-1143) |
| 05.19.2025 | McKesson asks district court to refund taxes in transfer pricing dispute (2025-1093) |
| 05.16.2025 | United States | New IRC Section 899 would increase tax rates and expand BEAT for certain inbound taxpayers (2025-1085) |
| 05.16.2025 | US House Ways and Means Committee approves tax reconciliation bill, including several international tax provisions (2025-1075) |
| 05.15.2025 | IRS reissues interim guidance on Advance Pricing Agreement submissions (2025-1063) |
| 05.13.2025 | US and China reach trade deal, as US Department of Commerce initiates investigation on aircraft and jet engines (2025-1051) |
| 05.09.2025 | US and UK unveil trade deal (2025-1026) |
| 05.09.2025 | United Kingdom | Trade deal with United States announced (2025-1025) |
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| 04.30.2025 | United States | Recent developments in US tariffs on automobiles and articles subject to tariffs (2025-0970) |
| 04.14.2025 | US exempts certain electronic products from tariffs under President Trump's Reciprocal Tariff Policy (2025-0893) |
| 04.11.2025 | US suspends President Trump's Reciprocal Tariff Policy for 90 days, except for China (2025-0868) |
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| 03.28.2025 | APA report for 2024 shows consistent number of APAs executed in less time (2025-0773) |
| 03.27.2025 | US President Trump announces 25% additional tariff on imported automobiles and automobile parts (2025-0767) |
| 03.13.2025 | European Union and Canada counter US steel and aluminum tariffs with retaliatory measures (2025-0659) |
| 03.07.2025 | US adjusts tariffs on Canada and Mexico in response to automotive industry concerns (2025-0626) |
| 03.06.2025 | G20 Finance Ministers' meeting discussion on international taxation (2025-0618) |
| 03.05.2025 | United States imposes additional tariffs on Canada and Mexico, raises additional tariffs on China (2025-0609) |
| 03.04.2025 | US initiates investigation into imports of timber, lumber and their derivative products (2025-0593) |
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| 02.26.2025 | US initiates investigation into imports of copper, scrap copper and copper derivatives (2025-0565) |
| 02.25.2025 | US initiates review of other countries' imposition of Digital Services Taxes on US companies and opens comment period on nonreciprocal trade arrangements (2025-0549) |
| 02.14.2025 | United States initiates review to determine reciprocal tariffs on all trading partners (2025-0483) |
| 02.13.2025 | President Trump announces review on reciprocal tariffs (2025-0468) |
| 02.05.2025 | IRS official affirms approach to periodic adjustments in recent general legal advice memorandum (2025-0397) |
| 02.03.2025 | United States issues Executive Orders imposing additional tariffs on Canada, Mexico and China (2025-0391) |
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| 01.31.2025 | United States | Proposed BEAT regulations would provide favorable guidance on qualified derivative payments in securities lending transactions (2025-0378) |
| 01.31.2025 | Updated 2024 US IRC Section 1256 qualified board or exchange list (2025-0374) |
| 01.31.2025 | Updated US list of foreign currency futures contracts - starting point for IRC Section 1256 (2025-0373) |
| 01.30.2025 | Switzerland and United States sign new Competent Authority Arrangement with implications for US 81-100 Group Trusts (2025-0362) |
| 01.24.2025 | IRS Office of Chief Counsel issues general legal advice memorandum on interaction among periodic adjustment, general arm's-length standard and best method rules (2025-0326) |
| 01.24.2025 | IRS publishes technical corrections to the proposed corporate alternative minimum tax regulations (2025-0306) |
| 01.24.2025 | CAMT technical corrections address AFSI adjustments for tax-exempt entities using the applicable corporation safe harbor (2025-0305) |
| 01.23.2025 | US issues Executive Order on BEPS 2.0 (2025-0304) |
| 01.22.2025 | United States President signs 'America First Trade Policy' Presidential Memo (2025-0294) |
| 01.22.2025 | US Customs and Border Protection proposes rule that would eliminate duty exemption for goods subject to punitive tariffs (2025-0292) |
| 01.21.2025 | United States | Final regulations on DPL rules retain proposed regulations' framework but include several modifications (2025-0288) |
| 01.21.2025 | United States | Treasury releases guidance package on classifying and sourcing digital content and cloud transactions (2025-0280) |
| 01.17.2025 | Treasury finalizes regulations on review of federal tax controversies by IRS Appeals office (2025-0269) |
| 01.16.2025 | US Customs and Border Protection publishes amendments for entry of low-value shipments (2025-0258) |
| 01.10.2025 | Abbott petitions Tax Court to redetermine deficiencies for 2020 (2025-0195) |
