Scope: United States
Proposed
Notice 2025-63: Proposed Regulations on Sourcing of Borrow Fees in Securities Lending and Repo Transactions
Treasury and IRS intend to issue proposed regulations specifying that certain borrow fees (and negative rebates) paid in securities lending or sale-repurchase (repo) transactions will be sourced based on the residence of the recipient. Applies to master agreement documented transactions in ordinary business or investment activities. Has implications for foreign investors, withholding, treaties, and financial institutions. Still proposed—formal rule not yet finalized.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 10, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Proposed
Notice 2025-63: Proposed regulations on sourcing of borrow fees in securities lending and sale-repurchase transactions
The IRS issued proposed regulations (Notice 2025-63) that will determine how certain borrow fees from securities lending and sale-repurchase transactions are sourced for U.S. tax purposes. This affects whether those fees are treated as U.S.-source or foreign-source income, with implications for withholding, treaty benefits, and cross-border investors. These are proposals, not yet final, and input from affected parties will help shape outcome.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 10, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Tax measures in 2026 budget including new transfer pricing rules and repeal of DST, enacted
Bill C-15 (Budget 2025 Implementation Act, No. 1) received Royal Assent on March 26, 2026. Key measures effective include new transfer pricing adjustments and documentation requirements for tax years beginning after November 4, 2025; repeal of the Digital Services Tax Act; enhancements to the SR&ED program; and anti-deferral/FABI rules affecting CCPCs and foreign affiliates. This reflects enacted policy affecting corporations with cross-border transactions and R&D-intensive businesses.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Modernization of transfer pricing rules under section 247 (Bill C-15)
Under Bill C-15 (Budget 2025 Implementation Act, No. 1), which received Royal Assent on March 26, 2026, Canada has significantly overhauled its transfer pricing provisions in section 247 of the Income Tax Act. Key changes include replacing previous rules with a single operative adjustment rule, aligning statutory interpretation with OECD Guidelines, reducing time to provide contemporaneous documentation to 30 days after request, raising penalty thresholds (lesser of $10 million or 10% of gross revenue), and introducing simplified documentation under prescribed conditions. These rules apply to taxation years beginning after November 4, 2025. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/transfer-pricing.html?utm_source=openai))
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Proposed
Penalty relief for tax year 2025 for reporting cash tips and overtime under the One, Big, Beautiful Bill
The Treasury and IRS issued guidance providing penalty relief to employers and other payors for tax year 2025 regarding new information reporting requirements for cash tips and qualified overtime compensation under the One, Big, Beautiful Bill (OBBB). This allows employers to adjust to new reporting rules without facing penalties immediately.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Notice 2025-62: Penalty Relief for Tax Year 2025 Reporting Requirements under the One, Big, Beautiful Bill
Under Public Law 119-21 (the One, Big, Beautiful Bill Act), new information reporting requirements for cash tips and qualified overtime compensation take effect for tax year 2025. Notice 2025-62 provides **transition penalty relief** for employers and other payors who fail to provide separate accounting of cash tips, occupation codes, or total qualified overtime compensation—so long as the remainder of the return or statement is complete and correct. This gives a transition period for systems to catch up while still requiring full returns. The relief is limited to the 2025 tax year. Implications include changes to payroll systems, statements to workers, and employer reporting practices.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: United Kingdom
Status requires verification
New Tax Credits for Electric Vehicle Purchases
A new tax credit program has been enacted to encourage the purchase of electric vehicles, providing up to £5,000 off the purchase price for qualifying vehicles.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Treasury, IRS Provide Penalty Relief for Tax Year 2025 for Information Reporting on Tips and Overtime Under the One, Big, Beautiful Bill
The Department of the Treasury and the IRS issued guidance providing penalty relief to employers and other payors for tax year 2025 regarding new information reporting requirements for cash tips and qualified overtime compensation under the One, Big, Beautiful Bill.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Expansion of the Critical Mineral Exploration Tax Credit eligibility to include additional minerals
Under Budget 2025, the eligibility of the Critical Mineral Exploration Tax Credit (CMETC) has been expanded to include twelve additional critical minerals, applying to expenditures renounced under flow-through share agreements entered after November 4, 2025 and on or before March 31, 2027; also the home accessibility credit and other tax expenditure changes align with first bracket rate cuts and top-up credits. This provides enhanced incentives for investment in exploration of critical minerals and clean technologies.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Luxury Tax Removed on Aircraft and Vessels under SLITA
Budget 2025 amendments to the Select Luxury Items Tax Act eliminate the luxury tax on **subject aircraft and subject vessels** effective **November 5, 2025**. Sales, importations, leases or improvements of those items will no longer carry luxury tax; registration and filing obligations cease for them, though audits and records continue during transition.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Status requires verification
Treasury, IRS provide penalty relief for tax year 2025 for information reporting on tips and overtime under the One, Big, Beautiful Bill
On November 5, 2025, IRS issued Notice 2025-62 giving employers and other payors **penalty relief** for failing to separately report cash tips, occupation codes, and qualified overtime compensation for tax year 2025 under the OBBB—provided they otherwise file accurate returns/statements. It’s a transition relief to ease compliance for 2025.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Changes to Child Tax Credit Eligibility
Recent legislation has modified the eligibility criteria for the Child Tax Credit, expanding benefits for families with lower incomes.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Global (United States)
Status requires verification
IRS issues penalty relief for new tips & overtime reporting requirements under the One, Big, Beautiful Bill
Treasury and IRS issued Notice 2025-62 on November 5, 2025, providing transition penalty relief to employers and payors for tax year 2025 regarding new information reporting requirements under the OBBB for cash tips and qualified overtime compensation. Employers who do not meet the new reporting requirements (e.g. separate accounting of cash tips, occupation coding) will not be penalized for returns/statements filed or provided for TY2025, as long as the rest is otherwise complete and correct. Reporting obligations apply but enforcement is delayed. This gives stakeholders time to implement new systems without immediate penalties.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Proposed
Elimination of luxury tax on subject aircraft and subject vessels under SLITA, effective November 5, 2025
As per Budget 2025, the luxury tax on subject aircraft and subject vessels is proposed to end as of November 5, 2025. Registrants/vendors of these items will no longer need to charge the tax, and after-sales improvements on those items will not trigger luxury tax. Registrations for these categories will be cancelled automatically by February 1, 2028. Filing obligations for reporting periods beginning after December 2025 are lifted under certain conditions. Subject vehicles remain taxable under SLITA. This change eases compliance burdens and reduces cost for buyers/sellers of aircraft/vessels.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Transfer pricing modernization under section 247 (Bill C-15)
Bill C-15 (Budget 2025 Implementation Act, No. 1), which received Royal Assent on March 26, 2026, modernized Canada’s transfer pricing rules: introduced a single operative adjustment rule replacing traditional vs recharacterization distinction; shortened timeline for contemporaneous documentation from 3 months to 30 days upon CRA’s request; raised penalty thresholds to the lesser of $10 million or 10% of gross revenue; added simplified documentation rules under prescribed conditions. Applies to taxation years beginning after November 4, 2025, affecting multinational enterprises and intercompany transactions.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Penalty relief for tax year 2025 reporting cash tips and qualified overtime under the One, Big, Beautiful Bill
Notice 2025-62 grants employers and other payors penalty relief for tax year 2025 with respect to new information reporting requirements for cash tips and qualified overtime compensation under the OBBBBA. Employers won’t face penalties for failing to provide occupation codes or separate accounting of tips/overtime so long as the overall return or statement is complete and correct. Allows transitional leniency while systems adapt.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Changes to the GST/HST Exemption for First-Time Home Buyers
The federal government has expanded the GST/HST exemption for first-time home buyers, increasing the threshold for eligibility effective January 1, 2026.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Transfer pricing changes under Bill C-15 (Budget 2025 Implementation Act) – section 247 reforms
Legislation (Bill C-15) modernized Canada’s transfer pricing rules under section 247: single operative adjustment rule, substance-based analysis, new documentation deadlines, higher thresholds for penalties, to align with OECD 2022 Guidelines.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Status requires verification
Treasury-IRS provide penalty relief for tax year-2025 for information reporting on tips and overtime under the One, Big, Beautiful Bill
In Notice 2025-62 (issued November 5, 2025), the U.S. Treasury and IRS provided transition-period penalty relief for tax year 2025 regarding new information reporting requirements under the OBBB Act for cash tips and qualified overtime compensation. Employers and payors will not face penalties for failing to separately report tip occupation or break out overtime pay when returns or statements are otherwise complete.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Introduction of the Carbon Tax Rebate Program
A new program designed to provide rebates to households affected by the carbon tax has been announced, aimed at easing the financial burden on families.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Nov 5, 2025
- Verification
- Not recorded
Open cited source