The U.S. Supreme Court ruled 6–3 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) are unlawful, holding that the President lacks authority to impose broad-based tariffs without clear congressional approval. With approximately $175 billion collected under these now-invalid tariffs, the government could face substantial refund exposure. Importers should begin reviewing their entries now, as refund procedures have not yet been announced.

The Tax Cuts and Jobs Act (TCJA) of 2017 brought significant tax reductions for individuals and businesses. However, many of its provisions are set to expire on December 31, 2025, leading to potentially higher tax burdens. Congress is currently debating potential extensions or modifications to certain provisions. We outline key changes and strategies to help you prepare.

A recent ruling in 2023 by the U.S. Court of Federal Claims allowed U.S. citizens living in France to offset the net investment income tax using the foreign tax credit for taxes that are paid in France. This outcome is different from a previous court case on this same issue. The IRS has appealed the ruling leaving taxpayers in limbo waiting on the final decision regarding the relationship between the net investment income tax and foreign tax credit.

On December 19, 2023, the U.S. Treasury Department announced that the U.S.-Chile Income Tax Treaty is now in force. The treaty provides for reduced withholding tax rates on interest, dividends, and royalties, as well as seeking to eliminate double taxation.

On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (“IRA”), designed to reduce inflation and provide investments in clean energy. The bill has several key provisions, one of which is a new 15% corporate minimum tax on large corporations.