EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Senate approves FY 2017 budget resolution with tax reform reconciliation instructions – Treasury Secretary, House Speaker expect tax reform in 2017 – Administration official says tax reform details negotiable, except 20% CIT rate and middle-class relief

A review of the week's major US international tax-related news. In this edition:US House Republicans remain committed to enacting tax reform in 2017 – Foreign minimum tax may be necessary to adopt US territorial tax system – Bipartisan group of House tax writers call for partial withdrawal of FIRPTA Notice 2007-55

A review of the week's major US international tax-related news. In this edition:US House and Senate Republicans move forward on reconciliation instructions for passage of US tax reform -- Senate Finance Committee holds hearing on international tax reform – US Treasury issues report on 8 tax regulations identified as burdensome, including debt/equity and FX regulations – IRS Notice 2017-57 announces deferral of applicability date of final Section 987 FX regulations.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans release tax reform framework -- IRS issues draft update of APA template – OECD releases first peer review reports on minimum standards on Action 14, improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Senate Budget Committee agrees on FY '18 Budget Resolution; implications for tax reform – "Big 6" tax reform consensus document released next week – US Treasury to publicly release report on "significant tax regulations" in September – IRS official upbeat on countries' implementation of OECD dispute resolution recommendations; concern over established transfer pricing principles.

A review of the week's major US international tax-related news. In this edition: US Tax Reform "consensus document" set for release week of 25 September – President Trump pushes for 15% CIT rate – Treasury/IRS Guidance Plan to be released in fall – Deadline for Treasury to report recommendations on "significant tax regulations" 18 September.

A review of the week's major US international tax-related news. In this edition: Congress approves bill to provide hurricane relief funding – President Trump calls for Democrats to join him in support of an "American Model" of tax reform – OECD releases further guidance on CbC Reporting – Lafayette G. "Chip" Harter III appointed deputy assistant secretary for international tax affairs for the US Treasury

A review of the week's major US international tax-related news. In this edition: Renewed push for US tax reform after Labor Day – Trump Administration expects Congress to take lead on reform legislation.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans to release details on tax reform in "short order" – "Big 6" negotiators looking for revenue for tax reform.

A review of the week's major US international tax-related news. In this edition: White House tax negotiators and congressional leaders plan to release document outlining framework for tax reform -- Congressional tax staffers to focus on anti-base erosion rules now that proposed border adjustment tax will not be adopted.

A review of the week's major US international tax-related news. In this edition: US corporate tax rate may settle in low to mid-20% range – IRS extends transition period for applying parts of Section 871(m) rules – IRS now accepting Form 8975, Country-by-Country Report and Schedules A.

A review of the week's major US international tax-related news. In this edition: Trump Administration outlines new strategy for enacting US tax reform – Kautter confirmed as new Treasury Assistant Secretary (Tax Policy) -- Tax Court holds US parent's CFCs held US property under Section 956 as result of intercompany transactions -- Tax Court rules IRS abused its discretion in cancelling two APAs – US concludes Competent Authority Arrangements for exchange of CbC reports with Australia and Estonia.

A review of the week's major US international tax-related news. In this edition: House border adjustability proposal no longer under consideration for US tax reform – Few repeal recommendations expected in final report on 8-Obama-era tax regulations deemed significant -- US signs 5 more Competent Authority Arrangements for automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House Budget Committee approves FY 2018 budget resolution with reconciliation instructions for US tax reform – White House official says "Big 6" and their staffs making headway on US tax reform – US Senate Finance Committee advances nomination of David Kautter for Treasury Assistant Secretary for Tax Policy -- US Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments; broad implications and possible refund claims -- Deadline approaching for certain MNCs to request suspension of MAP-related deadline under Mexico-US income tax treaty – OECD released updated version of Guidance on the Implementation of Country-by-Country Reporting.

A review of the week's major US international tax-related news. In this edition: Trump Administration wants draft tax reform plan "locked in place" before Congress' August recess – Senate Finance Committee and House Ways and Means Tax Policy Subcommittee to hold tax reform hearings next week -- OECD released draft contents of next update to OECD Model Tax Convention.

A review of the week's major US international tax-related news. In this edition: Robert Stack addresses prospect of territorial tax system at University of Oxford tax conference – Chairman Brady and Speaker of the House Ryan to possibly continue advocating for border adjustment tax – President Trump's nominee for Treasury assistant secretary for tax policy David Kautter moves forward – US IRS announces launch of CbC reporting on website with MNE implications.

A review of the week's major US international tax-related news. In this editio enate Finance Committee turns to US tax reform -- IRS finalizes Form 8975, Schedule A, Instructions for CbC Reporting – OECD to release new TP Guidelines, final report on branch mismatch structures, and MLI database.

A review of the week's major US international tax-related news. In this edition: US House Speaker calls for comprehensive, permanent tax reform in 2017 – IRS has signed 12 CA agreements for CbCR exchange – OECD releases discussion drafts on PE profit attributions, revised guidance on profit splits – OECD announces TP toolkit for developing nations lacking data.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman proposes 5-year border adjustability phase-in period – IRS considering ways to simplify FTIN process – IRS reconsidering transfer pricing case selection – US, Canada sign CbC competent authority agreement.

A review of the week's major US international tax-related news. In this edition: Trump Administration preparing detailed tax reform plan for Congress – US signed five competent authority agreements for exchanging CbC reports – US considering agreeing to and publicizing transfer pricing safe harbor rules – 68 jurisdictions signed Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary pressed on how to pay for tax reform – Congressional supporters of border adjustability proposal not giving up – OMB Director says Administration does not necessarily support deficit neutral tax reform.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means tax reform hearing focuses on border adjustability -- Senate Majority Leader expresses optimism for US tax reform -- Trump Administration releases $4.094 trillion FY 2018 Budget blueprint.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee held first hearing on tax reform in new Congress – W&M hearing on border adjustability proposal scheduled for 23 May – Trump Administration to release FY'18 Budget on 23 May -- US Treasury has begun review of final, temporary and proposed tax regulations issued after 1 January 2016 – Treasury moving tax regulations consistent with 'freeze' order -- US in tax treaty discussions with Ireland, Luxembourg, Netherlands, Argentina and Colombia.

A review of the week's major US international tax-related news. In this edition: Trump Administration officials discuss tax reform with Republican Senate Finance members – President Trump comments on border adjustability, suggests 10% repatriation rate – House Ways and Means Committee to hold tax reform hearing on 18 May – Trump Administration nominates Dave Kautter as Treasury Assistant Secretary for Tax Policy.

A review of the week's major US international tax-related news. In this edition: President Trump says Administration's tax reform plan is open to negotiation – House Republican goal now to develop single tax reform proposal palatable to both Administration and Congress – US Treasury making progress in negotiating competent authority agreements to exchange CbC reports -- OECD released update on exchange relationships for exchanging CbC reports.

A review of the week's major US international tax-related news. In this edition: Trump Administration releases tax reform plan -- President Trump signs Executive Order to review significant tax regulations issued since 1 January 2016 – US Tax Court rules modification of variable prepaid forward contracts does not trigger gain realization – IRS files notice of appeal in Medtronic transfer pricing case.

A review of the week's major US international tax-related news. In this edition: Trump Administration confirms tax reform in 2017 – White House to release tax reform plan "very soon" – Treasury may resume issuing tax regulations – President to sign Executive Order to review significant tax regulations issued in 2016.

A review of the week's major US international tax-related news. In this edition: Trump Administration to return to ACA repeal, then tax reform.

A review of the week's major US international tax-related news. In this edition: US tax reform, another health care deal dominated discussions before Congressional recess – IRS extended deadline for submitting QI, foreign withholding partnership, and foreign withholding trust agreement renewal requests -- IRS APMA issued 18th annual Advance Pricing Agreement report –- OECD released updated guidance on Country-by-Country Reporting.

A review of the week's major US international tax-related news. In this edition: President Trump and Congressional Republicans pivot to tax reform following ACA repeal failure – UK triggers Brexit; sets stage for complex negotiations with EU.

A review of the week's major US international tax-related news. In this edition: TUS House Ways and Means Committee Chairman expects Blueprint's border adjustability proposal will be included in US tax reform; but with phase-in and modifications – IRS to resume issuing "sub-regulatory" guidance – US Tax Court rules for Amazon.com, Inc., in transfer pricing cost sharing case – Country-by-Country Reporting update.

A review of the week's major US international tax-related news. In this edition: Tax reform takes backseat as Congress focuses on health care reform – Senate Majority Leader less optimistic for completing tax reform by August recess – Treasury official expects government to resume issuing tax guidance sooner, rather than later.

A review of the week's major US international tax-related news. In this edition: President Trump delivers address to Congress; US tax reform remains a priority – IRS issues draft instructions for new Form 8975, Country by Country Report, and accompanying Schedule A, Tax Jurisdiction and Constituent Entity Information.

A review of the week's major US international tax-related news. In this edition: President Trump holds meeting with CEOs of major retailers to discuss tax reform and border-adjustable tax proposal – Congressman Mike Kelly calls for a more methodical approach in trying to pass tax reform legislation to impose a border-adjustable tax – IRS official at recent International Tax Institute luncheon notes proposed Section 901(m) regulations include broader language than the original statute because they are meant to act as a catchall for transactions not targeted by Section 901(m) – IRS official at recent New York conference indicates the IRS will not be releasing any guidance other than most routine ones in the near future; practitioners caution that consolidated group members should ensure that they satisfy the Section 385 debt-equity documentation requirements – Steven Mnuchin sworn in as 77th US Treasury secretary.

A review of the week's major US international tax-related news. In this edition: President Trump to release comprehensive tax reform plan in coming weeks -- Japan confirms US limited partnership is fiscally transparent for Japanese tax purposes when applying US-Japan treaty.

A review of the week's major US international tax-related news. In this edition: US Senate will conduct its own tax reform process, not simply accept House bill -- IRS LB&I releases new compliance initiatives, including 3 international tax areas.

A review of the week's major US international tax-related news. In this edition: Donald Trump assumes the US presidency; comprehensive tax reform a priority – Final anti-corporate inversion regulations released – IRS issues temporary regulations denying nonrecognition treatment for contributions of appreciated property to partnerships with foreign partners – IRS issues final dividend equivalent rules – IRS Rev. Proc. 2017-23 provides details on CbC voluntary reporting.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Republicans finalizing open issues in Tax Reform Blueprint – OECD releases BEPS Action 6 Discussion Draft on treaty entitlement of non-CIV funds.

A review of the week's major US international tax-related news. In this edition: Tax reform and Obamacare repeal top Republican agenda as Congress returns to Washington – IRS releases extensive FATCA-related guidance.

A review of the week's major US international tax-related news. In this edition: Congress returns for 115th Congress and US tax reform debate – IRS issues final PFIC regulations – US, Argentina sign Tax Information Exchange Agreement.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says Republican tax reform plan will include border adjustability – Upcoming IRS LB&I audit campaign will include both inbound and outbound international tax issues -- Pending cross-border partnership transfer regulations will be effective for transfers occurring on or after 6 August 2015 – IRS Notice 2017-07 modifies effective date of deferral rules of Reg. Section 1.987-12(T).

A review of the week's major US international tax-related news. In this edition: Congressional Republican leaders offer insights into plans for US tax reform – IRS issues final regulations under Section 367 – Final Section 6038A regulations released.

A review of the week's major US international tax-related news. In this edition: Congress ends lame-duck session without Tax Technical Corrections – IRS issues Section 901(m) regulations limiting creditability of foreign taxes following covered asset acquisitions – IRS releases long-awaited regulations under Section 987 – IRS posted draft Form 8975, Country-by-Country Report, on IRS website.

A review of the week's major US international tax-related news. In this edition: President-elect Donald Trump names Steven Mnuchin as next Treasury Secretary -- House Ways and Means Committee Chairman offers details on development of a tax reform package – US, India reach agreement on first bilateral APA – OECD releases text of multilateral instrument under BEPS Action 15.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans bullish on prospects for US tax reform in 2017 – IRS to issue FATCA regulations package soon.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame-duck session following elections – Chances for comprehensive US tax reform improve – Treasury officials offer update on pending international guidance – Treasury looking at method for investment funds to prove US beneficial ownership for tax treaty purposes.

A review of the week's major US international tax-related news. In this edition: US election increases chances of comprehensive tax reform in 2017.

A review of the week's major US international tax-related news. In this edition: IRS issues package of Subpart F regulations – US to share summaries of unilateral APAs with foreign governments, following OECD BEPS recommendations.

A review of the week's major US international tax-related news. In this edition: US officials offer more insights into recent Section 385 debt/equity regulations – New FATCA Form W-8BEN-E required beginning 1 January 2017 -- Regulation package on Section 871(m) dividend equivalent payments and withholding rules coming, but not before mid-November.

A review of the week's major US international tax-related news. In this edition: Final and Temporary Section 385 debt/equity regulations significantly narrow scope of earlier proposed rules – US officials offer insights on Section 385 regulations – US government to focus on cross-border intangible property transfers for partnerships and corporations -- US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation if requirements met – OECD announces establishment of automatic info exchange relationships, global review of MAP programs.