EY Cross-Border Taxation Alerts

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.

OECD publishes Standard for Automatic Exchange of Financial Information in Tax Matters

A review of the week's major US international tax-related news. In this edition: Growing anti-inversion sentiment in Congress -- IRS issues final regulations under Section 861 -- CCA: IRS can notify w/holding agent of foreign taxpayer's incorrect claim of w/holding tax exemption -- OECD Council approves update to OECD Model Tax Treaty -- IRS official offers international guidance update.

There were several Mexican tax developments that took place on 4 July 2014, affecting maquiladoras among other changes.

A review of the week's major US international tax-related news. In this edition: Speculation on departures of top international IRS officials -- House Ways and Means Committee and Senate Finance Committee pass separate highway funding bills.

A review of the week's major US international tax-related news. In this edition: IRS releases FATCA guidance in run up to 1 July 2014 effective date -- Shakeup at the IRS Large Business and International Division -- US Congress to take up Highway Trust Fund after 4 July recess.

A review of the week's major US international tax-related news. In this edition: US and China reached agreement in substance on FATCA Model 1 IGA -- Corporate repatriation appears off radar to sustain Highway Trust Fund -- Final regs to change rules for failure to comply with GRAS, other filings "imminent".

A review of the week's major US international tax-related news. In this edition: Congress mulls repatriation to pay for Highway Trust Fund -- US Senate Foreign Relations Committee holds hearing on Spanish protocol, new Polish tax treaty -- Treasury official: Solutions for all BEPS issues may not be possible.

A review of the week's major US international tax-related news. In this edition: Congress mulls tax repatriation to pay for Highway Trust Fund -- FATCA audits to begin early 2016 -- European Commission begins state aid investigations for Ireland, Netherlands, and Luxembourg regarding corporate tax paid by three MNCs.

A review of the week's major US international tax-related news. In this edition: House, Senate leaders concerned about BEPS -- OECD Tax Conference confirms 2014 BEPS action items timeline -- Pending US tax treaties and protocols (again) blocked in Senate -- Finance Committee announces summer tax reform hearings -- Senate Majority Leader says tax extenders "dead" until after mid-term election -- IRS publishes list of registered FFIs; more FATCA guidance coming in June.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves more permanent tax extender bills; Chairman Camp moves to "incremental tax reform" approach -- IRS to permit financial institutions to use existing forms through 2014 to sort entity accounts for FATCA purposes.

A review of the week's major US international tax-related news. In this edition: US anti-inversion legislation introduced in House and Senate -- Update on tax extenders -- OECD holds two public consultations: on hybrid mismatch arrangements and TP documentation and country-by-country reporting -- Proposed 2013 US-Poland tax treaty transmitted to Senate.

A review of the week's major US international tax-related news. In this edition: Tax extenders and corporate inversions dominate Congressional tax debate – US government officials offer insights at ABA Tax Section meeting.

On 6 May 2014, a declaration on automatic exchange of information in tax matters was adopted at the meeting of the OECD Council at the Ministerial Level; it was endorsed by 48 countries and the EU.

In Notice 2014-33, the IRS announced it will treat calendar years 2014 and 2015 as a transition period for purposes of enforcing and administering implementation of FATCA by all withholding agents (including foreign financial institutions).

A review of the week's major US international tax-related news. In this edition: Proposed US tax agreements delayed in Senate (again) -- US-Spain protocol transmitted to Senate -- Senate to move on tax extenders package next week -- US corporate inversions attract Congressional attention -- IRS Proposed Section 381 regulations have international implications.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves six separate bills to make permanent certain expired business tax provisions -- IRS official says BEPS causing some treaty partners to take aggressive positions -- IRS's top FACTA priority is release of final forms and instructions.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to mark-up tax extenders soon -- Senate tax extenders bill to go to floor week of 28 April -- IRS Notice 2014-32 addresses foreign triangular reorganizations -- IRS extends expanded PFIC active banking exception for qualifying government bonds.

On 16 April 2014, the Australian Taxation Office (ATO) released two new draft transfer pricing Taxation Rulings and new two draft Practice Statements, which represent the ATO's first documented view on how the new transfer pricing laws will apply and what taxpayers need to do.

A review of the week's major US international tax-related news. In this edition: IRS announces filing exemption for US persons holding PFIC stock through exempt orgs / accounts -- Immediate action for Mexican IMMEX/maquiladora companies.

China and Germany on 28 March 2014 signed a new income tax treaty and protocol; it will become effective on or after 1 January following the year in which the new treaty enters into force.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee hearing reviews tax extenders -- Official offers US perspective on OECD BEPS action items,

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves tax extenders legislation -- House Budget Committee Chairman releases FY 2015 Budget Resolution -- IRS Announcement 2014-17 offers FATCA relief -- Senate Foreign Relations Committee reports five pending tax agreements out of committee -- OECD tentatively decides to make simplifications to CbC reporting template.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to mark-up tax extenders next week -- OECD issues digital economy discussion draft -- 34 countries commit to early adopt OECD Common Reporting Standard -- IRS says Bitcoin not a "real currency" -- US, HK sign TIEA.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to hold mark up of tax extenders package -- OECD releases discussion BEPS drafts on treaty abuse and hybrid mismatch arrangements - UK releases 2014 Budget.

On 12 March 2014, the Italian Government announced that the 20% flat tax currently applicable to dividends, interest, and certain capital gains will increase to 26%.

A review of the week's major US international tax-related news. In this edition: Update on US tax reform, tax extenders - OECD to issue discussion drafts on treaty abuse, digital economy, and hybrid mismatches in coming weeks.

The Italian Government, With Law Decree no. 16 of 6 March 2014, repealed part of the recently introduced tax rules concerning certain Digital Economy activities generally referred to as "Web Tax."

A review of the week's major US international tax-related news. In this edition: President Obama releases FY 2015 Budget -- IRS issues Notice 2014-14, announcing proposed Section 871(m) regulations will not apply to specified equity-linked instruments on 5 March 2014.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman releases comprehensive tax reform draft -- Senate Foreign Relations Committee holds treaty hearing -- President Obama to submit FY 2015 Budget Proposal on 4 March -- G20 expresses full support for OECD BEPS.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman Dave Camp poised to release comprehensive tax reform draft -- US Senate Foreign Relations Committee to hold long-awaited tax treaty hearing -- IRS issues final FATCA guidance.

On 11 February 2014, the Canadian government released the 2014 Federal Budget.

A review of the week's major US international tax-related news. In this edition: Chairman Camp expected to release comprehensive tax reform proposal before end of February -- Congress passes "clean" debt ceiling increase -- OECD releases "Standard for Automatic Exchange of Financial Account Information" -- IRS releases transfer pricing audit roadmap -- Canada issues 2014-2015 Federal Budget.

The US and Canada on 5 February 2014 signed an Intergovernmental Agreement (IGA) regarding the enhanced exchange of tax information in connection with the Foreign Account Tax Compliance Act (FATCA).

A review of the week's major US international tax-related news. In this edition: Future of US tax reform and tax extenders under a new Senate Finance Committee Chairman -- Prediction that US international tax reform will move forward in 2014 -- US signs FATCA IGAs with Canada, Hungary -- US debt limit reached 7 February -- EY to host webcast on OECD BEPS on 18 February.

A review of the week's major US international tax-related news. In this edition: President Obama to deliver State of the Union 28 January -- Treasury Secretary issues warning on debt limit -- Tax extenders legislative may be a possibility -- OECD hosts webcast on BEPS; digital economy focus not abandoned.

The Canadian government on 17 January 2014 launched a new Offshore Tax Informant Program targeting offshore tax evasion.