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As the Trump administration continues to roll out its sweeping tariff policy, the North American energy industry is working to address the effects of the President’s tariff strategy. The Trump administration intends to “unleash American energy,”¹ in part by imposing tariffs designed to remedy what the administration views as unfair trade practices and increase U.S. domestic energy production. The currently imposed and threatened tariffs will inevitably impact the energy industry and its consumers. The particularly relevant tariffs can be defined in two broad categories: (1) sectoral tariffs, in this case, imposed under Section 232 of the Trade Expansion Act of 1962, and (2) the country-specific and “reciprocal tariffs” that the Trump administration has imposed under the International Emergency Economic Powers Act.

On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance certain tax, spending, and debt limit legislation with a simple majority vote in the Senate so long as the legislation does not increase the federal budget deficit outside a 10-year budget window.

On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful Bill Act” (the “OBBBA”) — a comprehensive budget reconciliation bill — back to the House of Representatives, which voted in favor of the bill on July 3, 2025.

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”).

Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice.

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act.

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury and the Internal Revenue Service issued long-awaited proposed regulations (the “Proposed Regulations”) on the application of the corporate alternative minimum tax, which imposes a 15% corporate alternative minimum tax on the adjusted financial statement income (“AFSI”) of certain large corporations for tax years beginning after December 31, 2022.

Just eight weeks after former Chancellor Kwasi Kwarteng unexpectedly announced the largest package of tax cuts implemented in the UK since the 1970s, the UK Government has now effectively gone into full reverse following new Chancellor Jeremy Hunt’s Autumn Statement, delivered on 17 November 2022, in which he announced a £55 billion combined package of tax rises and spending cuts intended to shore up the UK’s public finances.

Following a highly negative response from the financial markets and the IMF, amongst others, to the UK Government’s “Growth Plan 2022” (released on 23 September 2022 by the then-new Chancellor Kwasi Kwarteng and summarised by us here) (the “Mini-Budget”), the replacement Chancellor Jeremy Hunt made an Emergency Statement on 17 October in which he announced, by way of a major Government “U Turn”, that almost all of the tax measures set out in the former Chancellor’s Mini-Budget would not now be implemented.