The US Congress returned to Washington this week from a week-long recess, taking up action on a limited budget reconciliation bill covering the Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) agencies of the Department of Homeland Security (DHS). The bill was released during the congressional recess.

A Senate floor vote may follow next week (week of 18 May) as lawmakers move to meet President Trump's call to complete the reconciliation bill by 1 June.

Consideration of a third budget reconciliation bill — perhaps in June or July — is also possible. Some congressional Republicans are urging a third budget bill to address party priorities ahead of the midterm elections in November. Such a bill could include the SAVE America Act voter ID bill and defense funding, social programs waste, fraud and abuse, and unspecified tax provisions as well as other measures.

The Senate Banking Committee on 14 May approved the Clarity Act (HR 3633), a bill establishing a regulatory market structure for cryptocurrency and other digital assets. The long-awaited markup of a bill establishing a digital-asset market structure passed on a bipartisan vote. Additional negotiations will be necessary for the bill to secure enough Democratic support to reach the 60-vote threshold on the Senate floor.

The Banking Committee's crypto bill must now be merged with the Senate Agriculture Committee's own product (which makes the Commodity Futures Trading Commission the chief regulator of digital assets) before coming to the floor.

US government officials, at the American Bar Association's annual Tax Section meeting in Washington, DC this week, provided numerous updates on pending international tax projects.

A senior Treasury official was quoted as saying that proposed regulations on the One Big Beautiful Bill Act (OBBBA) international tax transition rules will be released over the summer. The official urged taxpayers to comment quickly as the government hopes to finalize the guidance expeditiously. Recall that the IRS released four international OBBBA-related notices in late 2025.

The government is under a statutory time constraint. IRC Section 7805 permits Treasury to apply rules retroactively if they are released within 18 months of a provision's enactment. An official earlier this year said the government wanted to issue as many OBBBA international tax final regulations as possible within the 18-month window. The OBBBA was enacted in early July 2025.

IRS notices are also expected to be released this summer on other OBBBA-related changes, including IRC Section 951B downward attribution and IRC Section 904 expense allocation rules, which are not effective until the 2026 tax year.

Another Treasury official was quoted as saying the government plans to issue proposed regulations this summer that would amend the tax treatment of currency gains and losses under IRC Section 987. Recall that the IRS issued Notice 2026-17 in February 2026, announcing the government's intent to issue proposed regulations that would simplify the operation of the IRC Section 987 regulations and reduce compliance burdens, as well as refine the scope of certain rules to limit their effect on ordinary course of business transactions.

The official indicated the foreign currency guidance this summer would be limited to establishing an election under which controlled foreign corporations generally would not be required to compute or recognize IRC Section 987 gain or loss.

At another forum this week, a Treasury official was quoted as saying guidance would be issued "in the very near future" to clarify the applicability date in proposed rules under IRC Section 892 that were issued in December 2025. The proposed regulations address foreign governments' income from US investments.

The official said the coming guidance would protect existing investments and investment structures from being subject to the proposed rules. Government officials earlier this year indicated they wanted to avoid market disruption and retroactive application of the rules to existing transactions.

In the transfer pricing area, the head of the IRS Advance Pricing and Mutual Agreement Program said on 11 May that the government is "very, very, very far along" in updating Revenue Procedure 2015-41, covering advance pricing agreements and their administration.

Another guidance package on the corporate alternative minimum tax (CAMT) is now not expected to be released until early 2027, a senior Treasury official said. Also speaking at the ABA Tax Section meeting, the official confirmed that no additional CAMT guidance is expected until the next series of proposed regulations, perhaps in February 2027.

An IRS official at the meeting was quoted as saying the Trump Administration's interest in deregulation and reduction in compliance burdens could be reflected in the coming proposed CAMT rules. Those Administration priorities could result in additional safe harbors included in the proposed rules, an official said.

The US Federal Circuit this week issued a stay order temporarily reinstating the Trump Administration's 10% ad valorem global import tariff under Section 122 of the Trade Act of 1974. The stay allows the Trump Administration to resume collecting the tariff. The US Court of International Trade on 7 May held that President Trump exceeded his authority in imposing the temporary 10% ad valorem tariff.

President Trump on 20 February issued a proclamation that added a 10% ad valorem global import tariff on all articles imported, effective 24 February 2026 through 24 July 2026, unless expressly suspended, modified or terminated earlier, or extended by Congress.

The OECD on 18 May will release guidance to help multinationals that are facing challenges associated with jurisdictions' readiness for the upcoming June 30 global minimum tax filing deadlines.

Speaking at a tax conference in Washington on 15 May, Manal Corwin, director of the OECD's Center for Tax Policy and Administration, said negotiators "reached a common understanding among themselves, to mitigate the impact of any potential delays in the availability of fully operational portals to receive the [global information return]."

According to reports, the agreement will address multinational concerns over late-filing penalties, resulting from inconsistent global minimum tax implementation.

The OECD director was quoted as saying that, on 18 May, a new publication will include a list of countries that have global minimum tax rules effective for 2024 and that will have their global information return portals operational by 31 May.