17 July 2026

Report on recent US international tax developments — 17 July 2026

The US House Budget Committee on 16 July approved a budget resolution, the necessary first step in the development of a third budget reconciliation bill (3.0). The resolution for the US$95b bill does not contain instructions to the House Ways & Means Committee, meaning the framers do not expect to include a tax title in the bill.

The future of the budget resolution and the follow-on reconciliation bill in both chambers is uncertain. A House floor vote on the resolution is planned for next week — the last week the House is scheduled to be in session prior to the five-week August recess. The Senate is scheduled to be in session longer, but there are questions about how the resolution would be received in that chamber if it advances out of the House.

OECD officials this week provided updated estimates of the economic and revenue effects of the Pillar Two global minimum tax. During a 15 July webcast, OECD officials discussed new analysis estimating that tax revenue could increase by 3.2% to 5.4% of current average corporate income tax revenues, or US$91b to US$155b, annually. These estimates take into account the Side-by-Side Safe Harbor and the Substance-Based Tax Incentives Safe Harbor, which are part of the January 2026 agreement.

The officials were reporting on the results of updates to the OECD's Pillar Two economic impact assessment model, which they indicated show estimated revenue gains across all jurisdiction groups.

An OECD economist who spoke on the webcast also said effective tax rates (ETRs) are estimated to increase in most jurisdictions, with greater increases on average in countries that had lower ETRs before implementation of the global minimum tax. Profit shifting is estimated to drop by between 22.6% and 44.6%, according to another OECD official.

The OECD on 15 July published Taxation Working Papers No. 77, "MNE Responses to the Global Minimum Tax," providing an assessment of how multinational enterprises (MNEs) have responded to the introduction of the global minimum tax. The data, based on "realised responses of MNEs" using published financial data, covers the pre-implementation period 2022 — 2023, and 2024, which is the first year with global minimum tax rules in effect in some jurisdictions.

According to the OECD paper, which was also discussed on the webcast, MNEs have not reduced their investment or their employment at the MNE group level as a result of the global minimum tax initiative. The OECD also reports that analysis shows a post-implementation estimated increase in consolidated ETRs among in-scope MNEs of 1 to 2 percentage points.

A senior OECD official recently was quoted as saying the organization is testing a risk-assessment framework under which tax administrations could use global minimum tax information returns to identify MNEs considered low-risk that could then potentially be unselected for audit. According to the official, the goal would be to reduce audits using a systemic approach that is consistent.

The OECD is also reportedly planning to present to the Inclusive Framework this fall a proposal for a global mobility project, following the January 2026 public consultation discussion of issues and concerns relating to working cross-border.

The US Trade Representative on 15 July issued a Notice of Action under Section 301 of the Trade Act of 1974, imposing additional duties of 25% on imports of Brazil-origin goods, subject to specified exemptions. The final action concludes the Section 301 investigation initiated on 15 July 2025 into Brazil's acts, policies and practices.

The additional duties apply to products entered for consumption, or withdrawn from warehouse for consumption, on or after 22 July 2026. A Global Tax Alert provides details.

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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: 2026-1545