EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to release first tax reform draft within two weeks -- IRS rules there is a reduction in CFC's post-1986 foreign taxes corresponding to reduction in earnings from stock redemption.

On 30 October 2013, Law 16/2013 was published in the Spanish Official Gazette; it introduces relevant amendments to Spanish corporate income tax and extends the application of certain measures to FY 2014 and 2015.

A review of the week's major US international tax-related news. In this edition: House-Senate conference committee holds first meeting - Senate Finance Committee to release tax reform drafts in coming weeks - IRS issues Notice 2013-69 on FATCA - US, Hungary initial FATCA Model 1 IGA -- Mexican Congress approves tax reform

A review of the week's major US international tax-related news. In this edition: IRS rules certain growing activities qualify as production for subpart F foreign base company sales income rules -- ILM 201340016 considers triangular C reorg completed before release of Notice 2006-85 -- Update on Ireland's change to the Irish tax residency rules.

India's Central Board of Direct Taxes (CBDT) recently issued a notification for application of General Anti-avoidance Rules (GAAR).

Mexico's lower House of Congress revised and approved the proposed tax reform on 18 October 2013; it now moves on to the Senate for debate and vote.

A review of the week's major US international tax-related news. In this edition: Congress approves funding / debt bill; government reopens -- Ireland proposes change to tax residency rule to prevent "stateless" entities -- Italian Law Decree includes changes of interest to MNCs.

A review of the week's major US international tax-related news. In this edition: Movement on US fiscal impasse -- OECD country-by-country reporting may begin as early as 2014.

On 3 October 2013, the OECD published a memorandum seeking input on the development of an approach for country-by-country reporting of income, taxes paid, and economic activity.

An EY review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House; US opposes "virtual PE" concept and more.

A review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House -- US opposes "virtual PE" concept -- IRS concerned re: taxpayers unwinding so-called "sandwich structures" -- Two courts address STARS transactions.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans may tie movement on tax reform to legislation to raise the debt limit - Tax Court rules in BMC Software that accounts set up from Section 482 adjustment are related party indebtedness for Section 965 DRD.

In an opinion dated 6 September 2013, the European Council's lawyers concluded that the proposed Financial Transaction Tax counterparty rule is contrary to EU law.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess; no progress on fiscal issues -- IRS CCA looks at interest expense allocation / apportionment for FTC purposes -- Prop. regulations issued on limitations on importation of net built-in losses; international tax implications.

On 8 September 2013, Mexico's President Pena Nieto presented the long-awaited tax reform proposal to the Mexican Congress.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess to looming fiscal deadlines -- IRS issues final 901 regulations -- Final, temporary, and proposed regulations on application of straddle rules to debt instruments released.

A review of the week's major US international tax-related news. In this edition: US tax reform update -- IRS CCA concludes interest deductions on payments by US corporation to foreign parent disallowed under Section 267(a)(3) .

A review of the week's major US international tax-related news. In this edition: House and Senate committees continue work on tax reform during August recess -- IRS announces FATCA registration site available online.

A review of the week's major US international tax-related news. In this edition: US, Cayman Islands sign FATCA Model 1 IGA and TIEA -- IRS releases draft Form 8966 FATCA Report -- IRS releases PLR 201332007; addresses subpart F foreign base company sales branch rules.

A review of the week's major US international tax-related news. In this edition: A review of the status of US tax reform -- US, Belgium sign Competent Authority Agreement -- Urgent action by US and foreign MNCs may be required due to new Canadian upstream loan rules.

The Italian Revenue Agency issued its annual guidelines for Revenue auditors on goals to achieve and tax strategies to pursue in the carrying out of FY 2013 audit activities.

A review of the week's major US international tax-related news. In this edition: President Obama offers business tax reform proposal -- Congress begins August recess; tax reform markups for fall -- OECD issues TP discussion draft on intangibles, White Paper on documentation.

A review of the week's major US international tax-related news. In this edition: More on US tax reform and the recently released OECD base erosion and profit shifting (BEPS) action plan.

A review of the week's major US international tax-related news. In this edition: OECD released BEPS action plan on 19 July -- Treasury updated FATCA Model 1 and 2 IGAs -- IRS issues both FAA on CFC income from software leases determined to be foreign personal holding company income and GLAM on ADR Payments.

A review of the week's major US international tax-related news. In this edition: OECD to release BEPS action plan on 19 July -- Key FATCA timelines delayed -- Senate leaders say tax reform a long way off.

A review of the week's major US international tax-related news. In this edition: Congressional tax leaders kick-off of nation-wide tax reform tour -- OECD BEPS report due out next week -- IRS PLR addresses subpart F manufacturing exception -- IRS adds Croatian entity to per se list of corporations

A review of the week's major US international tax-related news. In this edition: Senate tax leaders favor "clean slate" approach to tax reform, FATCA developments, US Tax Court has jurisdiction to review APA cancellation, and US government opposes public disclosure of country-by-country tax reporting.

A review of the week's major US international tax-related news. In this edition: an update on the recent G8 meeting in Northern Ireland at which the G8 expressed support for greater transparency with tax authorities and endorsed the OECD's ongoing work on base erosion and profit shifting (BEPS).

The European Commission on 12 June 2013 proposed extending automatic exchange of information to cover dividends, capital gains, and other financial income and account balances.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee on 13 June held a hearing on US and foreign multinational corporations' use of tax havens, Congressional leaders stake out positions on raising US debt ceiling, and US, Japan sign Model 2 IGA "statement."

The Russian government recently released a draft document that discusses tax policy changes for 2014 and planning for the 2015-16 period.

A review of the week's major US international tax-related news. In this edition: OECD conference focuses on Base Erosion and Profit Shifting (BEPS), House Ways and Means moves a bit on US tax reform, and PLR 201321007 on domestication of a foreign parent corporation holding a USRPHC.

The European Union may be considering expanding tax reporting obligations already adopted for banks to all large companies and groups

United Nations launches Practical Manual on Transfer Pricing for Developing Countries

A review of the week's major US international tax-related news. In this edition: an update on the OECD's Base Erosion and Profit Shifting Action Plan, release of the UN Practical Manual on Transfer Pricing for Developing Countries, and IRS CCA 210321018.

A review of the week's major US international tax-related news. In this edition: the US Supreme Court rules the UK windfall tax is creditable, US FATCA developments, and the OECD's release of final guidance on transfer pricing safe harbors.

Australia issues 2013/14 Federal Budget

Swiss Corporate Tax Reform III: increasing Switzerland's attractiveness as a business location

A review of the week's major US international tax-related news. In this edition, A US official provides preliminary views on the OECD's base erosion and profit shifting report; IRS officials discuss upcoming US international tax guidance.

Canada Revenue Agency announces measures to counter international tax evasion and aggressive tax avoidance

A review of the week's major US international tax-related news. In this edition, an update on Congressional efforts on US tax reform.

South Africa continues increased scrutiny of PE exposure

A review of the week's major US international tax-related news. In this edition, an update on US tax reform, FATCA developments, and a new OECD handbook on transfer pricing.

A review of the week's major US international tax-related news. In this edition, speculation as to the future of comprehensive US tax reform following the announcement that Finance Committee Chairman Max Baucus (D-MT) will not seek re-election in 2014.

EU Developments: Platform for Tax Good Governance and proposed Financial Transaction Tax

A review of the week's major US international tax-related news. In this edition, an update on FATCA developments and an EU multilateral pilot program on tax information exchange.

France, Germany, Italy, Spain and UK announce tax information exchange pilot

A review of the week's major US international tax-related news. In this edition, an update on President Obama's FY 2014 Budget.

Australian tax developments

A review of the week's major US international tax-related news. In this edition, an update on an Obama Administration proposal that would exempt foreign pension fund gains from US tax under FIRPTA, and a new US-Norway competent authority agreement.