EY Cross-Border Taxation Alerts

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.

A review of the week's major US international tax-related news. In this edition: Obama Administration issues final and temporary debt/equity regulations under IRC Section 385 – OECD held public consultations on two discussion drafts: Additional Guidance on Profit Attribution to PEs and Revised Guidance on Profit Splits.

A review of the week's major US international tax-related news. In this edition: Final Section 385 debt/equity regulations sent to White House Office of Information and Regulatory Affairs for review -- House Ways and Means Committee Republicans again urge Administration to delay finalizing Section 385 regulations – US Treasury official strongly criticizes EU State aid investigations – EY global survey finds increasing audits and more aggressive enforcement from tax authorities around the world.

A review of the week's major US international tax-related news. In this edition: Congress adjourns until after November election; lame duck session expected – US, Argentina to begin tax treaty negotiations – IRS: Inbound asset reorganization in which US Parent acquired substantially all transferred corp's assets terminated GRA -- OECD final report on BEPS Action 14, Make Dispute Resolutions Mechanisms More Effective, to be released soon – OECD announces agreement in principle on Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: US government reaction to EU State aid investigations – House speaker expects tax reform in 2017 – IRS official predicts avalanche of MAP cases.

A review of the week's major US international tax-related news. In this edition: Congress returns from summer recess to short pre-election session – Treasury Secretary to meet with House Ways and Means Committee members on Prop. Section 385 debt/equity regulations – IRS issues Rev. Proc. 2016-46 providing foreign insurance guidance.

A review of the week's major US international tax-related news. In this edition: European Commission finds Ireland granted illegal State aid and orders recovery – US, Canada informally discussing joint audits – Congress returns to session after Labor Day.

A review of the week's major US international tax-related news. In this edition: Congressional Republican tax writers reiterate concerns over proposed Section 385 debt/equity regulations – US Treasury releases White Paper on European Commission's State aid investigations -- Ireland announces tax treaty talks with United States -- OECD releases discussion draft on branch mismatch structures under BEPS Action 2.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issued 2016-2017 Priority Guidance plan – IRC Section 5000(c) final regulations released on 2-percent excise tax on US government payments to foreign persons -- Treasury official confirms Administration can address unintended consequences in Proposed Section 385 debt/equity regulations.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Chairman comments on lawsuit against anti-corporate inversion regulations – US presidential candidates talk tax plans – ABA Section of Taxation submits comments on cloud computing.

A review of the week's major US international tax-related news. In this edition: US Treasury official says no set deadline for finalization of Section 385 debt/equity regulations – US, Singapore announce plans for reciprocal FATCA IGA with automatic info exchange, TIEA -- IRS announces IGAs not in force on 1 January 2017 will not be treated as in effect – US Chamber of Commerce files lawsuit challenging validity of anti-corporate inversion regulations.

A review of the week's major US international tax-related news. In this edition: Democrats hold National Convention in Philadelphia – IRS posts revised version chief counsel notice CC-2016-009 – Treasury and IRS officials discuss final CbC reporting regulations at July luncheon in Washington – Top officials at OECD tax policy symposium note that consistent implementation of the OECD's recommendations is key to reducing tax uncertainty – European Commission would like to see tougher standards for determining which territories should be on the tax haven blacklist.

A review of the week's major US international tax-related news. In this edition: Congress to reconvene after Labor Day – Treasury and IRS hope to finish guidance projects before Obama administration ends – Treasury Deputy Assistant Secretary (International Tax Affairs) Robert Stack notes there are four main areas where Section 385 regulations could have unintended results-- Andrew Hickman former head of the OECD's transfer pricing group, speaks at National Association for Business Economics Transfer Pricing Symposium in Washington.

A review of the week's major US international tax-related news. In this edition: IRS holds hearing on Proposed Section 385 debt/equity regulations -- OECD to present criteria to identify uncooperative jurisdictions for tax transparency purposes – Multilateral instrument to be opened for signature by end of 2016 -- Additional OECD BEPS discussion drafts coming.

A review of the EPS 's major US international tax-related news. In this edition: Treasury officials brief members of Congress on Proposed Section 385 debt/equity regulations – IRS issues proposed Qualified Intermediary Agreement – OECD releases BEPS documents for public comment.