12 June 2026

Report on recent US international tax developments — 12 June 2026

President Trump on 10 June signed the Secure America Act (S. 2) Customs Enforcement (ICE) and Customs and Border Protection (CBP) budget reconciliation bill (2.0). The US House on 9 June approved the Senate-passed legislation.

Attention now turns to whether congressional Republicans will attempt a third budget reconciliation bill this year (the One Big Beautiful Bill Act being the first). President Trump provided some impetus this week, calling in a 10 June social media post for a defense funding reconciliation bill that also includes voter ID legislation. While some House Republicans have voiced support for a third budget bill that could include tax measures, Senate Republicans have been cooler to the idea.

In addition to defense funding and the voter ID proposal, some Republicans envision a Reconciliation 3.0 bill that would include affordability proposals possibly offset with provisions to combat waste, fraud and abuse in federal safety-net programs. Members have floated other proposed items for potential inclusion, but there is currently no publicly announced working set of proposals.

The US House Ways & Means Committee held a 9 June hearing on "Digital Asset Taxation." Though the goal was to arrive at a bipartisan package, Democrats at the hearing were skeptical with support tepid. On 8 June, Committee members had introduced a series of six bills and a discussion draft addressing various cryptocurrency issues — a de minimis rule, mining and staking, charitable donations, wash sales and constructive sales among them.

Ways & Means Chairman Jason Smith (R-MO) reiterated prior comments that he only wanted to move forward on digital taxation legislation with bipartisan support. Ranking Member Richard Neal (D-MA) said his initial observation was that there are aspects of the bills that are sensible and would alleviate burdensome paperwork requirements. But he added that some of the proposals potentially provide cryptocurrency an unfair advantage. Members from both parties agreed that congressional inaction on the issue is not acceptable.

Chairman Smith said the Committee identified as primary issues that digital asset transactions, like mining and staking, do not fit clearly into existing tax law and digital assets do not receive the tax benefits available to traditional financial assets. Moreover, crypto owners face burdensome tax compliance and reporting that hinder using digital assets in ordinary commerce, Smith added.

In preparation for the hearing, the congressional Joint Committee on Taxation released a Digital Asset Taxation report (JCX-18-26) describing present law and the six bills and one discussion draft that were released.

In other crypto news, the US Tax Court held in Paschall, et ux. v. Commissioner, T.C. Memo. 2026-46, that cryptocurrency staking rewards constitute gross income in the tax year they are credited to a taxpayer's account. The court concluded that the taxpayer realized an accession to wealth over which he had dominion and control, even though the tokens were not sold or transferred during the year. The decision provides the court's first analysis of the federal income tax treatment of proof-of-stake rewards, using existing statutory and judicial income recognition principles applicable to all assets.

The OECD Inclusive Framework this week released guidance on the Global Anti-Base Erosion (GloBE) information return (GIR) electronic form. The document, titled "Tax Challenges Arising from the Digitalisation of the Economy — Guidance on the Use of the GIR XML Schema and Validation Rules for First GIR Filings and Exchanges" was issued on 8 June.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2026-1266