A senior US Treasury official told a European audience this week that rushing into a revised Pillar One solution would risk US support. Rebecca Burch, US Treasury deputy assistant secretary for international tax affairs, reiterated the US government position that although the United States wants open dialog with countries on addressing the digital economy, it is willing to take action against countries that impose unilateral digital services taxes.

She also told the audience that Pillar One is not the framework upon which to resume the discussion of the digital economy.

At the same meeting, OECD Secretary-General Mathias Cormann said the Inclusive Framework's steering group had "expressed a common desire" to discuss the taxation of the digital economy and avoid "harmful unilateral approaches."

The OECD official was quoted as saying that the currently stalled Pillar One discussions will resume this year. The OECD will be seeking input in the coming months on how countries' priorities have evolved in the years since the Pillar One project began.

On Pillar Two, the OECD plans to issue a broad range of global minimum tax guidance by mid-2026, according to Manal Corwin, director of the OECD's Centre for Tax Policy and Administration. Speaking on 19 March, the OECD director was quoted as saying the global anti-base erosion guidance will cover a number of areas, including integrity measures with respect to the simplified effective tax rate safe harbor as well as conditional taxes and related benefits.

Guidance is expected to be released on industry-specific areas as well as on hyperinflationary currencies.

The official added that the OECD is continuing work on a routine profits safe harbor and de minimum safe harbor to replace those tests in the transitional country-by-country reporting safe harbor.

The IRS this week extended temporary relief for identifying digital assets. In Notice 2026-20, the IRS extended through 31 December 2026 the temporary relief that allows taxpayers to use certain alternative methods for identifying digital assets sold or transferred through a broker. A Tax Alert is forthcoming.

A Treasury official this week said the government plans to issue new guidance on dividend equivalent amounts under IRC Section 871(m) sometime in 2026. The government has issued a number of notices on the subject over the last decade. Although the official did not provide details, he was quoted as saying that the notice regime has generally worked well and will be taken into consideration in the coming guidance.

And the IRS recently issued a statement to the effect that Treasury Secretary Scott Bessent is no longer the Acting IRS Commissioner but will continue to perform the duties of Commissioner until the vacancy is filled. The lifting of the acting commissioner designation was necessary to comply with time limits under federal law. IRS CEO Frank Bisignano remains in his post running day-to-day operations.