US: IRS, Treasury issues guidance to streamline interest capitalisation for property improvements
The guidance includes final regulations for eliminating the associated property rule and related provisions for interest capitalisation on improvements to designated property. The US Treasury and the Internal Revenue Service (IRS) have released
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US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
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US: IRS retracts proposed rules on corporate divisions, reorganisations
The U.S. Treasury and IRS have withdrawn the 30 September 2025 proposed regulations on corporate separations, incorporations, reorganisations, and multi-year tax reporting for related transactions. The U.S. Department of the Treasury and the
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Brazil, US sign agreement on automatic tax data sharing
The arrangement creates a formal system for Brazil and the U.S. to automatically share tax information under their 2007 agreement. The U.S. Internal Revenue Service (IRS) and Brazil have published a competent authority arrangement on 27 August
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US: Court of Appeals determines tax authorities cannot reallocate income beyond a taxpayer’s legal entitlementÂ
The IRS sought to reallocate an additional USD 23.7 million in royalties to 3M under the arm’s-length standard, despite the company’s Brazilian subsidiary being legally limited to paying only USD 5.1 million. The US Court of Appeals for the
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US: Trump weighs major tariff relief to boost US auto manufacturing
The proposal aims to cut costs for major U.S. carmakers by rewarding companies that assemble vehicles domestically, supporting Trump’s job creation goals. US President Donald Trump is considering a major tariff relief plan aimed at boosting US
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US: IRS extends filing, payment deadlines for taxpayers impacted by ongoing conflict in Israel
IRS is providing separate but overlapping relief to taxpayers who may be unable to meet a tax-filing or tax-payment obligation, or may be unable to perform other time-sensitive tax-related actions. The US Internal Revenue Service (IRS) announced,
See MoreUS: Treasury, IRS issue guidance on rural opportunity zone investments under the One, Big, Beautiful Bill
The guidance provides clarification on rural Qualified Opportunity Zone investments, which offer tax incentives to encourage economic growth and job creation in underserved areas. The US Department of the Treasury and the Internal Revenue Service
See MoreUS: IRS issues interim guidance on corporate alternative minimum tax (CAMT)
The two notices, Notice 2025-46 and Notice 2025-49, on 30 September 2025, provide interim guidance on the corporate alternative minimum tax (CAMT). ​​ The US Internal Revenue Service (IRS) issued two notices, Notice 2025-46 and Notice
See MoreUS: IRS, Treasury announce reduced user fees for tax professionals applying for or renewing PTINs, initiates public consultationsÂ
The US Treasury and IRS announced interim final regulations and a proposed rule to lower the user fee for tax professionals applying for or renewing a PTIN. The Department of the Treasury and the Internal Revenue Service (IRS) issued IR-2025-95
See MoreUS: Trump imposes 10% tariff on lumber, 25% on furniture and cabinets
Trump argued that these imports were undermining the US economy by threatening domestic wood mills, disrupting supply chains, and reducing the utilisation of American wood industries. US President Donald Trump signed a presidential proclamation
See MoreUS introduces ‘platinum card’ visa permitting 270-day stay with no foreign income tax
The Trump Platinum Card will allow individual applicants to reside in the US for up to 270 days per year without being subject to tax on non-US income. The US has unveiled plans for a "Platinum Card" that would enable foreign nationals to stay in
See MoreLesotho Trade Minister: US to extend Africa trade agreement for an additional year
This trade agreement provides African nations with preferential access to US markets. Lesotho's Trade Minister, Mokhethi Shelile, said, on 24 September 2025, that the US is planning to extend the African Growth and Opportunity Act (AGOA) by one
See MoreUS imposes 100% tariffs on branded pharmaceuticals, adds new tariffs on trucks and furniture
The Trump administration announced sweeping tariffs effective 1 October 2025, including a 100% duty on branded pharmaceuticals and 50% tariffs levied on trucks, cabinets, vanities, and 30% tariffs on upholstered furniture. President Donald
See MoreUS: Commerce Department launches tariff investigations on medical devices, robotics, machinery
The US Department of Commerce launched Section 232 investigations into imports of medical supplies, PPE, robotics, industrial machinery, and critical materials to assess domestic supply and foreign trade impacts, potentially raising tariffs. The
See MoreUS: IRS to end paper refund checks for individual taxpayers
The IRS and the Treasury announced that paper tax refund checks for individual taxpayers will be phased out starting 30 September 2025. The US Internal Revenue Service (IRS), working with the US Department of the Treasury, announced on 23
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Canada: PM Carney confirms US trade discussions to shift into USMCA review stage
Prime Minister Mark Carney stated that trade talks with the U.S. are ongoing, with several unresolved issues set to be addressed in the upcoming USMCA review. Canada’s Prime Minister Mark Carney announced yesterday, 23 September 2025, that
See MoreUS: IRS grants drought-related tax relief for farmers, ranchers across 49 states and beyond
Eligible farmers and ranchers whose drought-sale replacement period was scheduled to expire at the end of 2025 will have until the end of their next tax year to replace the sold or exchanged livestock. The US Internal Revenue Service (IRS) issued
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