17 April 2026 Report on recent US international tax developments — 17 April 2026 Congressional Republicans reportedly are discussing the possibility of moving a narrowly focused budget reconciliation bill that would address funding for Immigration and Customs Enforcement and Customs and Border Protection. Senate Majority Leader John Thune (R-SD) said on 14 April that Republicans plan to move quickly and decisively in regard to the legislation. The Majority Leader was further quoted as saying that a budget resolution — the first step in the budget reconciliation process — would come to the Senate floor the week of 20 April and would clarify whether tax measures will be included in the bill. House Majority Leader Steve Scalise (R-LA) was also quoted as saying Republicans are eyeing a third budget reconciliation bill (the One Big Beautiful Bill Act being the first) that would address other Republican policy priorities, including "ideally, some tax items." The US and Croatia reportedly have concluded negotiations on an amending protocol to the pending US-Croatia tax treaty. The US and Croatia signed a first-ever income tax treaty and protocol in December 2022. The proposed treaty, based on the revised US Model Treaty released in 2016, has not received US Senate approval. OECD Secretary-General Mathias Cormann issued a tax report to G20 Finance Ministers and Central Bank Governors on 16 April, announcing that Inclusive Framework (IF) jurisdictions will soon develop a system to determine if countries' Pillar Two measures "provide consistent outcomes with the GLoBE rules." The reviews will begin in second half of 2026. The Secretary-General further confirmed that the IF is updating the Global Information Return and related XML schema to address the "side-by-side" package announced early this year. The OECD Secretariat is supporting further signatures to the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GLoBE) Information with the goal of having a "wide network of exchange relationships in time for first exchanges in December 2026." The OECD Secretary-General reiterated that the IF is developing additional Pillar Two administrative guidance. The guidance will include so-called integrity provisions applicable for both the simplified effective-tax-rate safe harbor and the rules more broadly. Addressing an American Bar Association Tax Section meeting in Rome, Italy on 16 April, a senior OECD official was quoted as saying preparations are underway for a public consultation on transfer pricing for intragroup services to improve certainty. The draft is expected to be released in a few months. This work is being undertaken at a time when transfer pricing disputes involving financial transactions, intangibles, penalties and documentation are expanding. According to the OECD official, the immediate focus will be on Chapter 7 of the OECD Transfer Pricing Guidelines, which generally has not been addressed by the BEPS project. Areas of focus reportedly will include the benefit test and duplicative services, as well as pricing and shareholder activities. The official said: "Our intention is that every transfer pricing method can be applied to intragroup services the same way as any other transaction, so the most appropriate method should apply as well." And a senior OECD official this week said the organization is anticipating the US Treasury's pending cryptocurrency reporting regulations as it considers possible changes to the OECD's Crypto-Asset Reporting Framework (CARF). CARF is an international regime for reporting key information about a customer's digital asset transactions to its country of tax residence. It provides an automatic-exchange-of-information regime similar to the Foreign Account Tax Compliance Act and the Common Reporting Standard. The OECD official said the forthcoming US regulations would "test the waters" for the business community and provide valuable insights for the OECD. The official was also quoted as saying the OECD has a list of areas for improvement or further guidance relating to how CARF deals with issues such as nexus, tokenization and duplicative reporting, among others. Recall that President Trump's Working Group on Digital Asset Markets released "Strengthening American Leadership in Digital Financial Technology" on 30 July 2025, which included many recommendations that would affect tax reporting by digital asset brokers. Among other suggestions, the report said Treasury and the IRS "should consider proposing regulations" to implement CARF. By participating in CARF, the United States would receive data about US persons' digital asset accounts that are held outside the United States, while other countries would receive data from the IRS about their residents' digital asset accounts that are maintained in the United States.
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