14 September 2026 Americas Tax Roundup | 14 September 2026 | | | | A summary of the top weekly tax developments in the Americas | | | | | | | | | | | | | This week's tax news from the Americas - Canada announces counter-tariffs in response to new US tariffs
Following the US decision to impose a new 50% tariff on CA$27.6b of Canadian goods effective 22 August 2026, Canada’s Minister of Finance and National Revenue announced on 25 August 2026, that Canada will impose additional Canadian tariffs on US goods. The counter-tariffs cover CA$27.6b in imports from the United States, effective 8 September 2026, with a focus on sectors that are most affected by US tariffs. The government also introduced a CA$7.5b package of new support measures for Canadian workers and businesses, particularly small and medium-sized businesses, in sectors most affected by the new US tariffs.
- United States bans importation of certain Canadian alcoholic beverages, dairy and motor vehicle products, modifies scope of goods subject to existing 50% duties
On 8 September 2026, the US President signed five proclamations under Section 338 of the Tariff Act of 1930 (Section 338), escalating the US response to Canadian measures affecting imports of US alcoholic beverages, dairy products and motor vehicles. Three proclamations prohibit importation of specified Canadian-origin goods that are currently subject to the additional 50% Section 338 duties, effective for covered products imported on or after 12:01 a.m. Eastern Time on 29 September 2026. Two proclamations modify the scope of the products subject to the 50% duties, removing goods such as rock salt and cement and adding others, including all-terrain vehicles (ATVs) and additional dairy products, effective 15 September 2026. Covered products imported before 29 September 2026 but not yet entered for consumption, or withdrawn from warehouse for consumption, remain subject to the 50% duty rather than the prohibition.
- Curacao Parliament passes Pillar Two legislation
On 1 September 2026, the Parliament of Curacao passed the Minimum Tax Ordinance, implementing the Pillar Two framework of the Organisation for Economic Co-operation and Development; the Ordinance will formally enter into force upon publication in the Official Gazette and is expected to apply retroactively for fiscal years beginning on or after 1 January 2025. The Ordinance introduces a non-domestic Income Inclusion Rule (IIR), but not a Qualifying Domestic Top-up Tax or Undertaxed Profits Rule. Additionally, a Side-by-Side Safe Harbor would apply for fiscal years beginning on or after 1 January 2026, which could reduce Curacao IIR top-up tax to nil for groups with a United States ultimate parent entity.
- Canada extends suspension of federal excise tax on fuel
On 2 September 2026, Canada announced it will extend the current suspension of the fuel excise tax levied under Part III of the Excise Tax Act, which has been in effect since 20 April 2026. The tax holiday will continue to apply to gasoline, unleaded aviation gasoline, leaded aviation gasoline, diesel fuel and aviation fuel for which the tax becomes payable on or after 8 September 2026 and before 1 February 2027. Additionally, a reduced rate of tax will apply from 1 February 2027 through 31 March 2027.
- US Customs and Border Protection seeks comments on heightened import disclosure and supply-chain-visibility requirements
In an Advance Notice of Proposed Rulemaking issued on 2 September 2026, the US Customs and Border Protection invited public comments on measures that would significantly expand import disclosure, recordkeeping and supply-chain-transparency requirements. Measures under consideration include requiring importers to obtain and retain documentation that foreign exporters submit to their customs authorities, as well as collecting additional identifying information about manufacturers, producers, shippers, exporters and other parties involved in each importation. Comments are due by 1 December 2026, and any resulting rulemaking could significantly affect importer compliance programs, data-collection systems and customs recordkeeping obligations.
- United States | Federal Circuit Court of Appeals holds taxpayers may not offset US net investment income tax with foreign tax credit
The Federal Circuit Court of Appeals held that US citizens living abroad may not use foreign tax credits for income taxes paid to a foreign country to offset the net investment income tax (NIIT) under IRC Section 1411. The court concluded that IRC Sections 27 and 901(a) allow taxpayers to use foreign tax credits to offset Chapter 1 taxes, but not the NIIT, as it is imposed under Chapter 2A. The court also held that the treaties do not create a foreign tax credit independent of the Internal Revenue Code because Article 24 of the treaties subjects treaty relief to US statutory restrictions.
- United States | Proposed regulations would implement OBBBA's overhaul of CFC pro-rata share rules
On August 25, 2026, the US Department of the Treasury and the Internal Revenue Service proposed regulations (REG-115646-25) that would implement revisions to the pro-rata share rules, which were enacted under the One Big Beautiful Bill Act (OBBBA). The proposed regulations would set forth new rules for determining US shareholders' pro-rata shares of a CFC’s subpart F income and tested income or tested loss, including new allocation methodologies and new requirements or elections to close tax years. Additionally, they would extend those rules to IRC Section 951B and sunset the “extraordinary reduction” regulations under Treas. Reg. Section 1.245A-5. The proposed regulations would also address the transition rule for certain pre-OBBBA dividends by adopting the framework in Notice 2025-75.
| | | | | | | This week's newsletters - Trade Lines - 3 September 2026
Our trade newsletter for global business leaders delivers timely insights into the issues shaping global commerce—from tariff shifts and supply chain disruptions to legislative developments and compliance trends.
| | | | | | | Upcoming EY webcasts A calendar of all upcoming EY webcasts is available. | | | | | | | Recent EY podcasts All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts. | | | | | | | This week's EY Global Tax Alerts Americas Middle east | | | | | | | | | Additional resources EY Global Tax News Update
EY's Global Tax Alerts and other content can be delivered directly to your inbox. Register for EY's Global Tax News Update. | EY Guides available for download
Browse our in-depth guides covering corporate tax, indirect tax, personal taxes, TP and other tax matters in more than 150 countries. |
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: 2026-1936 |
