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01 May 2026 Report on recent US international tax developments — 1 May 2026 The US House approved the Senate's FY2026 budget resolution on 29 April, paving the way for a slim reconciliation bill to fund the Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) agencies of the Department of Homeland Security (DHS). (Separately, the House approved an earlier-passed Senate bill to fund the rest of DHS, aside from ICE and CBP.) Conservatives' efforts to broaden the scope of the budget resolution beyond ICE and CBP were not successful. The budget resolution does not include reconciliation instructions to either the Senate Finance or House Ways & Means Committees with jurisdiction over tax, trade and healthcare, precluding those items from being added to a future bill. The House and Senate are scheduled to be in recess next week, after which the reconciliation process will continue. Senate Majority Leader John Thune (R-SD) was quoted as saying he hopes to have a floor vote on the slimmed-down reconciliation bill the week of 18 May. There also continues to be speculation over a possible third reconciliation bill that would follow the ICE/CBP budget reconciliation measure and last year's One Big Beautiful Bill Act. The US Treasury Department on 28 April announced that the United States and Croatia signed a protocol to amend the pending US-Croatia income tax treaty and protocol that was signed in December 2022. The proposed 2022 treaty and protocol have not received US Senate advice and consent. Financial institutions should confirm they are collecting account holders' tax identification numbers to comply with automatic exchange-of-information requirements under the Foreign Accounting Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). The IRS extended relief under FATCA for reporting missing tax identification numbers through 2027, but foreign tax authorities have recently been issuing compliance notices requiring financial institutions to take specific actions if those numbers are missing from filings. New self-certification requirements under the CRS, which took effect 1 January 2026, mandate the collection of valid self-certifications that include tax identification numbers and other key information for both account holders and controlling persons. Financial institutions should review and enhance their due diligence, reporting and validation procedures so they comply with both FATCA and CRS, particularly in preparation for 2027 reporting. A Tax Alert provides details. The OECD on 30 April released a new Global Minimum Tax Implementation Toolkit. The toolkit covers important administrative aspects of the Global Minimum Tax, including timelines and milestones. It also addresses "common operational challenges and promotes coordination through shared best practices" that are meant to reduce administrative and compliance burdens. According to an OECD news release, the toolkit does not interpret or modify the global minimum tax standards. The toolkit project was led by the OECD Forum on Tax Administration with input from the OECD/G20 Inclusive Framework. The OECD also released updated Frequently Asked Questions (FAQs) on the Global Anti-Base Erosion (GloBE) Rules and the Global Minimum Tax.
Document ID: 2026-0975 | ||||