Nomadic Tax Institute

Policy updates

Publicly sourced cross-border tax developments. Dates, status and scope are shown separately so they can be read in context.

2645 updates

Scope: United States

Status requires verification

Classification of Digital Content Transactions and Cloud Transactions

Final regulations modifying rules under Treasury Regulations §§1.861-18 and 1.861-19 to require classification of digital content and cloud transactions using a predominant character test rather than de minimis rules. Affects sourcing of income under international tax provisions and applies for taxable years beginning on or after January 14, 2025.

Editorial impact label: High

Published
Not recorded
Policy event
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Effective
Jan 14, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

IRS Announces Tax Relief for Taxpayers Impacted by Wildfires in California; Various Deadlines Postponed to Oct. 15

The IRS provided tax relief for individuals and businesses in Los Angeles County affected by wildfires, extending filing and payment deadlines to October 15, 2025.

Editorial impact label: Medium

Published
Not recorded
Policy event
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Effective
Jan 7, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Treasury, IRS provide transitional guidance for 2025 for businesses reporting car loan interest under the One, Big, Beautiful Bill

Notice 2025-57 offers penalty relief and temporary guidance for lenders in 2025 on information reporting for interest received on qualified passenger vehicle loans. Lenders may satisfy reporting obligations by furnishing statements (online, monthly, annual) rather than filing full returns during 2025. This eases compliance during the first year of the new section 6050AA rules under OBBB. High impact for lenders and borrowers of car loans.

Editorial impact label: Medium

Published
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Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Transitional Guidance for Interest Reporting on Specified Passenger Vehicle Loans under Section 6050AA

Notice 2025-57 provides transitional relief to lenders/recipients for calendar year 2025 reporting obligations under new §6050AA of OBBB. Recipients who receive ≥ $600 interest from individuals for specified passenger vehicle loans must report that interest, and furnish statements to individuals, but for 2025 can meet obligations by making a statement available by January 31, 2026. Penalties under §§6721/6722 will not be imposed if done according to this relief.

Editorial impact label: Medium

Published
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Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: Global (United States)

Status requires verification

Treasury, IRS provide guidance for individuals who received tips or overtime during tax year 2025

Notice 2025-69 clarifies how workers can claim a new deduction for qualified tips and overtime compensation in tax year 2025 even when those amounts are not separately reported on employer information returns. It establishes maximum deduction limits ($12,500 for individuals, $25,000 for joint filers), provides phase-out thresholds based on modified adjusted gross income, and includes illustrative examples to guide eligibility. This change is part of the "One, Big, Beautiful Bill" and is effective immediately for tax year 2025.

Editorial impact label: Medium

Published
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Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Treasury, IRS issue final rules identifying certain partnership related-party "basis shifting" transactions as transactions of interest

Final regulations issued that identify certain partnership related-party ‘basis-shifting’ transactions (e.g. via partnership distributions or transfers among related partners) as ‘transactions of interest’ (TOIs), triggering disclosure requirements. The threshold for what qualifies for this increased substantial basis increase is $25 million for tax years before 2025, and $10 million thereafter. This affects both partnerships and material advisors, with implications for tax planning and potential penalties for non-disclosure.

Editorial impact label: Medium

Published
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Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Final regulations on backup withholding on third-party network transactions

Under regulations implementing section 3406 and 6050W as amended by the One, Big, Beautiful Bill Act, backup withholding on payments via third-party settlement organizations now only applies when payees exceed both $20,000 in gross payments and 200 transactions in a calendar year. Reporting and withholding thresholds reverted from the $600 threshold under ARPA. These final regulations took effect for payments in calendar years beginning after December 31, 2024.

Editorial impact label: High

Published
Not recorded
Policy event
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Effective
Jan 1, 2025
Verification
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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

Notice 2025-62 gives employers and other payors relief from penalties for tax year 2025 when filing requirements for cash tips and qualified overtime compensation under the OBBB law aren’t met. Reporting must be complete and otherwise correct; forms W-2/1099 won’t reflect new reporting yet.

Editorial impact label: High

Published
Not recorded
Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Notice 2025-62: Penalty Relief in Connection with New Reporting Requirements for Qualified Tips and Qualified Overtime Compensation

Notice 2025-62 provides relief from penalties under IRC § 6721 and § 6722 for taxable year 2025 related to the new information reporting requirements added by OBBBA for qualified tips and qualified overtime compensation. Taxpayers using good faith efforts to comply will avoid penalties for that year.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Guidance for individuals who received tips or overtime for tax year 2025 under the One, Big, Beautiful Bill

Under OBBB, taxpayers can deduct qualified tips and qualified overtime compensation in tax years 2025 through 2028, with annual limits and income phase-outs; today’s guidance clarifies how to determine deductions without separate employer accounting and provides transition rules for reporting forms. Big change for tipped and overtime-earning workers.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

IRS/Treasury provide penalty relief for 2025 information reporting on tips and overtime under the One, Big, Beautiful Bill

Treasury and IRS issued guidance (Notice 2025-62) granting employers and other payors transition‐period penalty relief for tax year 2025 for failing to provide correct information returns or payee statements reporting cash tips, overtime compensation, and occupation codes. Employers are encouraged to prepare for future compliance though Forms W-2/1099 are not updated for 2025.

Editorial impact label: High

Published
Not recorded
Policy event
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Effective
Jan 1, 2025
Verification
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Open cited source

Scope: Canada

Proposed

Canada proposes automatic tax returns filing for certain low-income individuals

Budget 2025 proposes amending the Income Tax Act to allow the CRA to file tax returns on behalf of eligible individuals whose income is below specified thresholds and who meet certain criteria, giving them 90 days to review. This would simplify access to benefits and reduce administrative burden. ([budget.canada.ca](https://www.budget.canada.ca/2025/report-rapport/tm-mf-en.html?utm_source=openai))

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
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Open cited source

Scope: Canada

Proposed

Elimination of the Underused Housing Tax (UHT) starting calendar year 2025

Budget 2025 proposes to eliminate the UHT for the 2025 calendar year and thereafter, meaning no UHT returns required and no tax payable for tax years on or after 2025; obligations remain for 2022-2024. High impact for property owners, non-resident investors, and those with vacant or under-used real estate. ([budget.canada.ca](https://www.budget.canada.ca/2025/report-rapport/tm-mf-en.html?utm_source=openai))

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source

Scope: United States

Status requires verification

Transitional Guidance Regarding Returns Relating to Certain Interest on Specified Passenger Vehicle Loans Received in a Trade or Business

Notice 2025-57 gives transitional guidance under section 6050AA of the Internal Revenue Code for calendar year 2025. Lenders receiving interest from individuals on qualifying passenger vehicle loans (over $600) may satisfy reporting obligations by providing a statement of total interest received rather than full detail, and are granted penalty relief under secs 6721/6722 for this limited form of reporting.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
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Open cited source

Scope: Canada

Proposed

Elimination of Underused Housing Tax As of 2025 Calendar Year

Budget 2025 proposes to eliminate the Underused Housing Tax (UHT) effective for the 2025 calendar year. Starting then, no UHT payable and no UHT returns required. However, requirements and penalties continue for calendar years 2022-2024. This reduces compliance and tax burden for non-resident, non-Canadian owners of residential real estate. Impact: medium for foreign investors.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source

Scope: Global

Status requires verification

Non-taxability of Canada Carbon Rebates for Small Businesses

Draft legislation introduced in June 2025 to ensure that Canada Carbon Rebates for Small Businesses in fuel charge years 2019-20 to 2023-24, and the final 2024-25 payment, are **not** included in taxable income for corporations. Once enacted, affected corporations may amend past T2 returns accordingly.([canada.ca](https://www.canada.ca/en/department-finance/news/2025/06/government-confirms-non-taxability-of-canada-carbon-rebates-for-small-businesses.html?utm_source=openai))

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source

Scope: United Kingdom

Status requires verification

Applying VAT to private school fees and boarding services

From 1 January 2025, all education and boarding services provided for a charge by private schools (or connected persons) will be subject to VAT at the standard rate of 20%. Pre-payments of fees for terms starting 1 January 2025 made from 29 July 2024 are subject to VAT. The move ends long-standing exemptions and impacts fee quoting, billing and parental expectations. Schools will need to register for VAT where thresholds are exceeded, adjust invoicing systems, and determine how to communicate changes to stakeholders. Special provisions exist for prepayments and for pupils with EHCP under certain conditions.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source

Scope: Global

Status requires verification

Budget 2025 proposes to eliminate the Underused Housing Tax as of the 2025 calendar year

Canada’s government proposes ending the Underused Housing Tax (UHT) so that no UHT is payable and no returns required for calendar year 2025 and onwards; obligations for prior years still apply.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
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Open cited source

Scope: Australia

Proposed

Increased Tax Offset for Low-Income Earners

The government has proposed an increase in the tax offset for low-income earners to provide additional financial relief amid rising living costs.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source

Scope: Global

Status requires verification

Treasury, IRS provide transition relief for businesses reporting car loan interest under the One, Big, Beautiful Bill

Notice 2025-57 provides relief for interest reporting on qualified passenger vehicle loans for calendar 2025. Lenders and businesses are required to report under section 6050AA, but the IRS will not impose penalties if a statement showing total interest is provided by 31 January 2026.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Jan 1, 2025
Verification
Not recorded

Open cited source