18 May 2026 Americas Tax Roundup | 18 May 2026 | | | | A summary of the top weekly tax developments in the Americas | | | | | | | | | | | | | EY US offices are closed 22 May to 25 May. The next Americas Tax Roundup will be published on 26 May. This week's tax news from the Americas - Canada | Budget 2025 implementation Bill No. 2 tabled in House of Commons
On 6 May 2026, the Canadian government introduced Bill C-31, Budget 2025 Implementation Act, No. 2 (Bill C-31), in the House of Commons, implementing various Budget 2025, income tax, global minimum tax and indirect tax measures. Notably, the business income tax and global minimum tax measures in Bill C-31 are considered substantively enacted for financial reporting purposes as of 6 May 2026, reflecting the federal government's new majority status. Key effective dates vary by measure, including 31 December 2023 for certain foreign affiliate, foreign accrual tax and foreign tax credit amendments, 4 November 2025 for measures such as immediate expensing for eligible manufacturing or processing buildings and certain anti-avoidance rules, and 1 January 2026 or later for certain global minimum tax safe harbor rules.
- Canada | Employee ownership trusts are here to stay
Canada’s federal Spring Economic Update 2026, introduced on 28 April 2026, signals that employee ownership trusts (EOTs) are set to become a permanent fixture. More specifically, the federal government announced that the exemption on the first CA$10m of eligible capital gains realized on the sale of a business to an EOT, which was scheduled to expire for dispositions of shares occurring after 2026, will be made permanent. The proposal was subsequently included in Bill C-30, Spring Economic Update 2026 Implementation Act, which received first reading in the House of Commons on 29 April 2026.
- Spain and Brazil reach mutual agreement on the treaty characterization of interest on net equity payments
Spain's Ministry of Finance has published a note reporting that Spain and Brazil have reached a mutual agreement clarifying the treaty treatment of Brazilian interest on net equity (INE). Under this interpretative agreement, INE is to be treated as "interest," and should not enjoy participation exemption as provided for in Article 23 of the Spain-Brazil Tax Treaty. The clarification was reached as an interpretative agreement, which implies that it could be applied retroactively.
- Saudi Arabia and United States enter into Tax Information Exchange Agreement
On 14 April 2026, Saudi Arabia and the United States (US) signed a Tax Information Exchange Agreement (TIEA) to facilitate the exchange of tax-related information relevant to the administration and enforcement of tax laws in both jurisdictions. The TIEA aims to strengthen cooperation between the Saudi Arabia Ministry of Finance and the US Internal Revenue Service by enabling the exchange of taxpayer information for compliance and enforcement purposes. The TIEA enables the competent authorities of both countries to request and share information relevant to tax matters, including income tax, zakat, value-added tax, excise tax, and other federal taxes. It establishes procedures for information exchange upon request and provides a framework that allows for automatic exchanges subject to separate mutual agreement between the competent authorities.
- OECD releases toolkit to support tax administrations in applying Pillar Two and updates FAQs
On 30 April 2026, the Organisation for Economic Co-operation and Development (OECD) released The Global Minimum Tax Implementation Toolkit (the Toolkit) to support tax administrations with establishing a robust and efficient domestic Pillar Two compliance framework. The Toolkit is structured as a roadmap to the key steps and actions that tax administrations commonly undertake in implementing the Global Minimum Tax, setting out a series of implementation steps, each elaborated through complementary models. The Toolkit was developed by the OECD Forum on Tax Administration, with insights from delegates of the OECD/G20 Inclusive Framework. It builds on the Global Anti-Base Erosion Model Rules and other standards agreed by the Inclusive Framework. It does not interpret or modify the application or interpretation of these standards.
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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: 2026-1081 |
