EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Senate Finance tax reform working groups release final reports, including international tax – US, Vietnam sign first-ever tax treaty.

A review of the week's major US international tax-related news. In this edition: Congress to return from recess to tackle Highway Trust Fund; repatriation, international tax reform possible revenue sources -- Deadline for Senate Finance Committee's tax reform working groups pushed to early July -- World Customs Organization publishes Guide to Customs Valuation and Transfer Pricing – Possible 'Grexit' has FX implications.

A review of the week's major US international tax-related news. In this edition: House W&M subcommittee hearing looks to repatriation to fund Highway Trust Fund – Senate Finance Committee working group on international tax reform hands in report – Legislation introduced to close PFIC "loophole" reportedly used by US hedge fund reinsurers.

A review of the week's major US international tax-related news. In this edition: W&M Chairman says US international tax reform and making tax extenders permanent will dominate 2015 tax agenda in Congress -- IRS may require CbC reports to be filed with corporate returns in September 2017 – Public comments on proposed changes to US Model Tax Treaty due 15 September 2015.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group will present findings on 26 June -- House Ways and Means Committee international tax reform component will propose hybrid territorial tax system with broad innovation box – Congressional tax leaders relay concern over BEPS to Treasury – OECD releases CbC reporting implementation package – G7 Leaders reaffirm commitment to BEPS.

A review of the week's major US international tax-related news. In this edition: IRS issues final anti-corporate inversion regulations – OECD issues discussion draft on BEPS Action 8 on hard-to-value intangibles -- Seven countries join OECD agreement to exchange financial information automatically.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups receive deadline extension -- DC Appeals Court rules 1% federal excise tax on reinsurance premiums inapplicable to retrocession agreements between foreign entities -- IRS reiterates US corporation in outbound F reorganization prior to effective date of Notice 2012-39 must recognize gain on IP -- OECD releases revised discussion draft on BEPS Action 6 on prevention of treaty abuse.

A review of the week's major US international tax-related news. In this edition: US Treasury releases new Model Tax Treaty provisions – US business tax reform in 2015 may be limited – OECD releases revised discussion draft on Action 7, artificial avoidance of PE status.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee international tax reform legislative text expected this summer -- US District Court in Lehman Brothers disallows FTCs in back-to-back stock loan transaction – ABA Tax Section meeting highlights coming US international tax guidance – OECD Update: public consultation held on BEPS Action 12 on mandatory disclosure rules, OECD's Pascal Saint-Amans takes aim at multinational tech companies.

A review of the week's major US international tax-related news. In this edition: Senate passes House-Senate conference report with reconciliation instructions – IRS issues Rev. Rulings 2015-09 and 2015-10 clarifying certain cross-border internal restructurings.

A review of the week's major US international tax-related news. In this edition: IRS this week releases Notice 2015 – House of Representatives on 30 April passes the House-Senate conference agreement on the FY 2016 budget resolution addressing tax reform and tax extenders – the OECD releases discussion draft on cost contribution arrangements in connection with Action 8 (transfer pricing aspects of intangibles) under its Action Plan on BEPS.

A review of the week's major US international tax-related news. In this edition: IRS issues proposed PFIC insurance regulations that address Senate Finance Committee member's concerns – IRS releases proposed regulations under Section 5000C – IRS CCA 201516064 clarifies short term loan exception under IRS Notice 88-108.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group reviewing options - IRS confirms interaction of PFIC look-through rules in PLR 201515006 - OECD releases discussion draft on Action 11(Improving the analysis of BEPS).

A review of the week's major US international tax-related news. In this edition: Congress returns from 2-week recess; Senate Finance tax reform working groups resume work -- OECD releases Discussion Draft on CFC rules under Action 3.

A review of the week's major US international tax-related news. In this edition: OECD releases Discussion Draft on Action 12 (Disclosure of aggressive tax planning arrangements) – US officials comment on BEPS Actions 8, 9, 10.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee leaders offer international tax reform insights -- OECD holds public consultation on BEPS Actions 8-10 on transfer pricing -- US will focus on international tax administration and mutual agreement procedures post-BEPS.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee focuses on international tax reform – Fifth Circuit Court of Appeals reverses Tax Court in BMC Software; A/R created following transfer pricing adjustment does not constitute indebtedness for Section 965 purposes – US Treasury official: 25 countries may be interested in mandatory binding arbitration based on multilateral instrument.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee Chairman has concerns over Obama Administration's international tax proposals – Finance Committee requesting tax ideas on tax reform; international hearing slated for 17 March -- IRS to begin scheduling pre-filing conferences for bilateral APAs with India – US opposes risk, recharacterization, and special measures draft under BEPS actions 8, 9, and 10, but consensus still possible.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee ranking member releases report on tax avoidance through financial products, deferred compensation – US to release updates to 2006 model tax treaty in draft form – OECD consensus building on BEPS Action 4 on interest deductions.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups set May deadline – Treasury officials offer US positions on OECD BEPS.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman says tax reform in 114th Congress must happen before August recess -- IRS concludes US shareholder must increase its E&P in year of Section 951(a)(1) inclusion -- IRS opines on application of tax rate disparity test for foreign sales branches – US anti-corporate inversion regulations may be released in 2015 – New IRS APMA director appointed.

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations under Section 909 on foreign tax credit splitting events --- China issues long-awaited indirect transfer rule replacing Circular 698

A review of the week's major US international tax-related news. In this edition: Obama Administration releases FY 2016 Budget, including international tax proposals – Ways and Means Committee holds hearing on proposed FY 2016 Budget – Treasury official offers insight on future anti-inversion regulations – OECD releases three more BEPS papers.

A review of the week's major US international tax-related news. In this ed(See attached file: 04 - Week ending 30 Jan.wav.zip)ition: President Obama to release FY 2016 Budget on 2 February - Finance Committee Chairman Orrin Hatch offers insights on tax working groups, international tax reform.

A review of the week's major US international tax-related news. In this edition: Obama Administration, Congressional Republican leaders stake out positions on future tax reform debate – US, India agree on framework to resolve competent authority cases; clears way for US-India APAs.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans talk tax reform – President Obama to deliver State of Union Address on 20 January -- The Stop Tax Haven Abuse Act reintroduced in Congress -- IRS launches FATCA International Data Exchange Service.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes -- Sen. Hatch assumes chairmanship of Finance Committee -- FATCA developments -- IRS CCA 201501013: Foreign fund's activities through US fund manager constitute US trade or business.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes 6 January – IRS releases PLR 20145200002 on FTC recapture.

A review of the week's major US international tax-related news. In this edition: President Obama announces Administration will release specific proposals on tax reform – Tax extenders legislation signed into law – IRS releases final regulations (T.D. 9707) with respect to filing of Form 5472.

A review of the week's major US international tax-related news. In this edition: Congress enacts tax extenders legislation -- Obama Administration may release detailed business tax reform plan in 6-9 months - Incoming Senate Finance Committee Chairman discusses guidelines for tax reform -- IRS officials offer thoughts on inversion guidance -- OECD releases 6 BEPS discussion drafts.

A review of the week's major US international tax-related news. In this edition: Congress poised to pass tax extenders legislation -- Incoming Senate Finance Committee Chairman releases tax reform report -- OECD BEPS update -- IRS updates FATCA Q&As on withholding certification forms -- SEC says more disclosure about foreign taxes may be necessary -- UK releases more details on diverted profits tax proposal; significance for US multinationals.

A review of the week's major US international tax-related news. In this edition: House approves one-year tax extenders legislation -- IRS announces jurisdictions treated as having FATCA IGA, but not yet signed, will retain status beyond 31 December 2014 -- UK Autumn Statement includes new 'diverted profits tax' proposal.

A review of the week's major US international tax-related news. In this edition: Congressional negotiators reach tentative tax extenders deal; President Obama threatens veto -- OECD releases public discussion draft on follow-up work on treaty abuse under BEPS Action 6.

A review of the week's major US international tax-related news. In this edition: Tax extender negotiations continue in Congress -- Rep. Paul Ryan to chair Ways & Means Committee, Sen. Orrin Hatch to lead Finance Committee in 114th Congress -- IRS issues final and temporary regs on failure to file timely GRAs, other reporting; IRS Directive on GRAs revoked -- IRS issues CCA 201446020 on back-to-back loans to avoid Section 956.

A review of the week's major US international tax-related news. In this edition: Congress begins lame-duck session; tax extenders under negotiation -- House may consider REIT/PFIC change -- IRS finalizes regulations on all-cash D reorganizations -- Treasury continues work on anti-inversion guidance -- Treasury considering limited FATCA relief for IGAs in substance -- BEPS communique expected following G20 Finance Ministers meeting -- UK, Germany release IP proposal -- OECD releases BEPS strategy for including developing countries.

A review of the week's major US international tax-related news. In this edition: Obama Administration continuing to move forward on potential guidance to curb corporate inversion transactions -- 51 jurisdictions pledge to abide by automatic tax information exchange.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee considering need for anti-inversion stop gap measure -- US Claims Court in Albemarle rules contested foreign tax liability accrues in year to which it relates, not year resolved and paid.

A review of the week's major US international tax-related news. In this edition: Treasury notifies 17 Model I IGA jurisdictions of MFN option -- IRS CCA 201441015 disallows domestic parent's deemed paid foreign taxes paid -- Ireland's FY'15 Budget includes improvement to IP regime, phasing out of "double Irish".

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-58 on economic substance -- FATCA developments reviewed -- OECD updates calendar for draft BEPS discussion papers, public consultations -- EY conference participants polled on BEPS.

A review of the week's major US international tax-related news. In this edition: US government officials offer perspectives on OECD BEPS action items.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-52 to counter corporate inversions -- Treasury considering expanding covered asset acquisition rules under Section 901(m); PFIC guidance coming -- EY Alerts / Webcasts on OECD BEPS deliverables available -- Congress adjourns for mid-term elections; lame duck session may bring tax technical corrections.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS deliverables in 7 focus areas -- Obama Administration confirms it will address inversions shortly.

A review of the week's major US international tax-related news. In this edition: Congress returns from August recess; focuses on anti-inversion options -- OECD to release first seven deliverables under BEPS Action Plan on 16 September 2014 -- IRS issued CCA 201436047; accrued but unpaid interest is an obligation under Section 956 -- IRS Notice 2014-51 announces PFIC marked to market exception

A review of the week's major US international tax-related news. In this edition: Congress returns next week from August recess -- OECD to release multiple BEPS reports and recommendations during week of 15 September.

A review of the week's major US international tax-related news. In this edition: IRS releases 2014-2015 Priority Guidance Plan -- IRS finalizes rules applying straddle rules to certain debt instruments -- IRS addresses when late-received documentation can support portfolio interest exemption.

A review of the week's major US international tax-related news. In this edition: Congress returns after Labor Day for short session -- Proposed anti-inversion legislation expected in September.

A review of the week's major US international tax-related news. In this edition: Senator Charles Schumer releases outline of his legislative proposal to address inversions by targeting earnings stripping practices -- IRS releases its first private letter ruling on Section 7874 anti-inversion rules – IRS issues Revenue Procedus pa014-47 that provides guidance for entering into a withholding foreign partnership agreement and withholding foreign trust agreement with the IRS -- EY publishes a Global Tax Alert discussing the Standard for Automatic Exchange of Information in Tax Matters paper released by the OECD on 21 July 2014.

A review of the week's major US international tax-related news. In this edition: Congressman Levin releasesdiscussion draft of legislation that would tighten the earnings stripping rules of Section 163(j) -- Obama Administration reviews possible actions that could limit companies' ability to engage in inversions – OECD releasesreport on the impact of BEPS in low income countries -- OECD seeking input on collecting and analyzing data on BEPS as part of Action 11 of BEPS Action Plan.

A review of the week's major US international tax-related news. In this edition: Congress mulls anti-inversion options -- IRS will apply forthcoming FTC regulations to certain entity classification elections following covered asset acquisitions -- OECD BEPS report on digital economy will not propose new tax regime.

A review of the week's major US international tax-related news. In this edition: Corporate inversions dominate Senate Finance Committee hearing -- IRS Notice 2014-44 announces forthcoming regulations under Section 901(m) -- IRS names acting director of transfer pricing operations -- OECD publishes Standard for Automatic Exchange of Financial Account Information in Tax Matters.