Treasury has published the boycott list again after a seven month gap, and the eight countries on it are the same ones it named in 2021
Eight countries. The same eight.
Treasury published its current list of countries that require or may require cooperation with an international boycott on Monday, and it names Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria and Yemen. The notice is a page long. It carries no footnote, adds nobody and removes nobody, and it is signed by James Wang, International Tax Counsel at the Office of Tax Policy.
The list is required by section 999(a)(3) of the Internal Revenue Code, which is short enough to quote whole: the Secretary shall maintain and publish not less frequently than quarterly a current list of countries which require or may require participation in or cooperation with an international boycott.
Quarterly is the standard, and the last twelve months did not meet it
The previous notice ran on 19 May. Before that, 6 April. Before that, 11 March.
And before that, nothing since 31 July 2025, an interval of seven months and eleven days across which no list was published at all. Then three appeared inside ten weeks, and this one comes eighty three days after the May edition. None of the notices says why, none of them acknowledges the gap, and this item is not going to invent a reason for it.
The last time the list changed was April 2021
The eight countries have appeared, in that order and with no other country beside them, in all twenty three notices published since the start of 2021.
The change that ended the previous run is on the face of the April 2021 notice, which states that the United Arab Emirates was removed because of Federal Decree-Law No. 4 of 2020, repealing the law that mandated a boycott of Israel, and because of what the notice calls the subsequent actions the UAE government has taken to implement the new policy. The October 2020 edition had listed the UAE ninth and said Treasury was monitoring the situation there, the country having announced a decree repealing its boycott law. That is the entire published record of movement in more than five years.
What being on the list actually does
It is not a sanctions list, and this is the part most often read the wrong way round. Nothing on it is prohibited.
What section 999 does is impose a reporting duty and then price a behaviour. Under subsection (a)(1) a person with operations in, or related to, a listed country reports those operations, and under subsection (a)(2) reports whether it participated in or cooperated with a boycott, or was asked to. The form is Form 5713, the International Boycott Report.
The money follows the behaviour rather than the geography. Where there is participation or cooperation, the Code computes an international boycott factor and uses it in three places: a denial of foreign tax credit under section 908(a), an addition to subpart F income under section 952(a)(3), and a deemed distribution under section 995(b)(1)(F)(ii). A company can trade in all eight countries and owe nothing under any of them.
The reporting duty is also wider than the list. Subsection (a)(1) reaches any other country where the taxpayer knows or has reason to know that cooperation is a condition of doing business, which means the eight names are a floor rather than the boundary.
The document
Treasury filed the notice on 7 August for publication on 10 August. The list is one page, and the statute behind it is section 999.
