21 February 2025

Report on recent US international tax developments — 21 February 2025

President Trump this week seemed to endorse the House Budget Committee's FY2025 budget resolution. Posting on social media on 19 February, the President wrote that the House Resolution implements his full America First Agenda, and he wants "both Chambers to pass the House Budget to 'kickstart' the [Budget] Reconciliation process." The House will return to Washington next week from its Presidents' Day recess and may take up the committee's budget resolution, although House Speaker Mike Johnson (R-LA) said the House vote could slip "by a few more days."

Recall that both the House Budget Committee and Senate Budget Committee last week advanced their own FY2025 budget resolution. The House resolution — preferred by President Trump — provides for a $4.5t net instruction that will cover a 10-year extension of expiring Tax Cuts and Jobs Act provisions. It has been suggested that other tax proposals, including those put forward by President Trump, could be paid for with other revenue offsets, such as paring back Inflation Reduction Act energy tax credits and, reportedly, limiting the corporate state and local tax deduction.

The full Senate, which was in session this week, passed its FY2025 budget resolution early on 21 February. The Senate resolution provides only for budget reconciliation to address border, energy and defense issues, leaving tax for a second reconciliation bill. Senate Republicans are positioning their budget resolution as a backstop if the House's single reconciliation bill approach hits a roadblock.

According to reports, President Trump shortly will release a memorandum that will set the stage for US retaliation against countries that have enacted digital services taxes that could be imposed on US companies. The memorandum reportedly directs the US Trade Representative to consider actions that could be taken against those countries. Tariffs would not be implemented immediately, and the memo will not include a timeline for when the duties could be effective.

President Trump on 19 February signed an Executive Order (EO) titled Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Regulatory Initiative. The EO directs federal agencies to "initiate a process to review all regulations subject to their sole or joint jurisdiction for consistency with law and Administration policy," and within 60 days identify those that are unconstitutional, are "based on unlawful delegations of legislative power," among other criteria.

Addressing trade, President Trump on 18 February suggested that auto and semiconductor chip tariffs are forthcoming. Asked what the auto tariff rate should be, President Trump said "it'll be in the neighborhood of 25%." Asked about semiconductors and pharmaceuticals, the President said, "it'll be 25% and higher, and it'll go very substantially higher over a course of a year." The President indicated he wants first to give companies the opportunity to establish their operations in the United States before imposing the higher tariffs.

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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: 2025-0537