10 July 2026 Report on recent US international tax developments - 10 July 2026 The US Congress returns from the Fourth of July recess on 13 July, with the House having only eight legislative days until its scheduled August recess (the Senate is in for an additional week). Budget reconciliation 3.0 — including the potential for tax provisions — continues to garner support among some Republican members of Congress as well as with President Trump. Enacting a third budget bill is generally seen as an uphill effort, however. In addition to establishing the necessary support in both the House and Senate, a budget bill faces a tightening congressional calendar with the focus increasingly turning to the looming November mid-term elections. A senior US Treasury official commented on 8 July at the International Tax Conference Munich 2026 that public country-by-country reporting (CbCR) is "very dangerous" due to the possible misinterpretation of data. Rebecca Burch, Treasury deputy assistant secretary for international tax affairs, was quoted as saying the problem with public CbCR is that "it is going to get into the ethos of policymakers that MNEs who are paying an adequate amount of tax are not, and there will be nothing you can do" to fight that misperception. In another session at the same conference, Burch defended the Pillar Two side-by-side agreement against claims it gives the United States a competitive advantage. She was quoted as saying the agreement is not a preferential deal but rather a recognition that the US already has a system in place for imposing a minimum tax on global income. A senior OECD official said recently that a coming OECD report will show a reduction in tax revenue estimates with respect to Pillar Two, which is viewed as resulting from the substance-based tax incentive safe harbor. The OECD is expected to release an economic income assessment of the global minimum tax this month, which will update previous assessments and will be based on data from the first year (2024) that Pillar Two rules were in effect. The OECD official described the coming report as also reflecting more accurate modeling and the latest information on implementation of the Global Anti-Base Erosion (GloBE) rules. Addressing the recent 30 June deadline imposed by many jurisdictions requiring in-scope multinationals to file their Pillar Two global information returns and GloBE notifications, a senior OECD official this week acknowledged there were "significant compliance and administrative challenges." Manal Corwin, director of the OECD's Centre for Tax Policy and Administration, expressed the belief, however, that the "the vast majority of returns were successfully filed on time." The US, Canada and Mexico have in recent months met virtually to discuss whether to renew the US-Canada-Mexico Agreement (USMCA) for another 16-year term. The US ultimately did not agree to renew the trade agreement in its current form. Rather, the parties used the 1 July 2026 review deadline to take stock of the agreement and confirmed that discussions will continue. It is worth underscoring that the USMCA did not expire, nor was it automatically renewed for another 16 years The agreement is currently scheduled to expire on 1 July 2036; the practical result is that there is no immediate disruption, but there will be continued uncertainty over the agreement's long-term path. Worth noting, the US and Mexico formally began bilateral review discussions earlier this year, while the US and Canada have had more informal discussions to address priorities, with cautious optimism that those discussions will eventually formalize.
Document ID: 2026-1468 | ||||