EY Cross-Border Taxation Alerts

A review of this week's major US international tax-related news. In this edition: US Tax Court rules taxpayer entitled to DRD, but limits foreign tax credit.

A review of this week's major US international tax-related news. In this edition: IRS issues new proposed regulations that limit / modify taxpayers' FX elections – UN Committee advances Terms of Reference for convention on international tax cooperation.

A review of this week's major US international tax-related news. In this edition: US economic and tax policy become focus in Presidential race – IRS issues early draft form for brokers to report digital assets sales and exchanges – IRS expanding Compliance Assurance Process program to privately held corporations, including foreign-owned – OECD releases transfer pricing framework for lithium.

A review of this week's major US international tax-related news. In this edition: US Treasury and IRS issue proposed DCL regs addressing BEPS Pillar Two, other issues.

A review of this week's major US international tax-related news. In this edition: US Congress adjourns for August recess – Senate fails to move Tax Relief for American Families and Workers Act with international provisions – G20 / Central Bank Governors communiqué reiterates support for BEPS 2.0 project

A review of this week's major US international tax-related news. In this edition: US House begins summer recess, Senate has additional week – DC Circuit Court of Appeals reverses Tax Court; FP's gain from inventory on US partnership disposition is foreign-source – IRS official comments on pending CAMT guidance – PTEP regulations in the 'home stretch.'

A review of this week's major US international tax-related news. In this edition: US IRS releases final Section 367(b) regs addressing cross-border triangular reorganizations, inbound nonrecognition transactions – Congress reacts to Supreme Court's Loper Bright decision invalidating Chevron – OECD Inclusive Framework close to finalizing MLC text on Pillar One Amount A, expanded Amount B framework.

A review of the week's major US international tax-related news. In this edition: IRS issues procedural final regulations on stock repurchase excise tax – IRS releases final digital asset broker reporting regs, transitional relief for certain brokers – Canada's DST in force, US legislators react – OECD releases draft BEPS 2.0 User Guide for GloBE information return XML Schema.

A review of the week's major US international tax-related news. In this edition: US Supreme Court ends court deference to agency interpretations of ambiguous laws, including tax laws – US House Republican Tax Team on global competitiveness to hold first field meeting with stakeholders on 8 August, White Paper to follow – IRS will address DCL income allocation rules in context of BEPS Pillar Two global minimum tax jurisdictional tax blending – US, Switzerland sign new FATCA Model 1 agreement – US Treasury and OECD officials offer insights on BEPS 2.0 Pillar One and Pillar Two project.

A review of the week's major US international tax-related news. In this edition: US Supreme Court upholds validity of IRC Section 965 mandatory repatriation tax – US Treasury Department suspends key provisions of US-Russia Tax Treaty and Protocol – IRS issues package on certain related-party partnership basis shifting transactions – OECD/G20 Inclusive Framework releases documents on BEPS Pillar One Amount B and Pillar Two.

A review of the week's major US international tax-related news. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – IRS again extends penalty relief for failure to pay estimated CAMT.

A review of the week's major US international tax-related news. In this edition: US IRS officials discuss pending CAMT, stock buy-back regs – BEPS Pillar One Amount B package to be finalized soon – OECD releases updated FAQs on ICAP program.

A review of the week's major US international tax-related news. In this edition: OECD will release two more rounds of BEPS Pillar Two GloBE administrative guidance – US will not sign Pillar One MLC until India and China agree to unresolved transfer pricing issues.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee launches new TCJA public comment portal – US opposes annual billionaire global wealth tax proposal – IRS notice extends Section 871(m) transition relief for dividend equivalent transactions – IRS to defer applicability date of some provisions in Sections 59A and 6038A regs for qualified derivative payments – Section 6045 final crypto reporting regulations coming in 2024 – OECD committed to open BEPS Pillar One multilateral convention for signature in June – Work continuing to finalize BEPS Pillar One Amount B provisions.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Chair working with Majority Leader to bring tax bill to Senate floor – CBO releases new revenue estimate on TCJA extension – White House National Economic Advisor offers insights into Biden Administration tax policy

A review of the week's major US international tax-related news. In this edition: US Ways and Means Chairman says all current TCJA measures will be on the table in 2025 – Treasury official says proposed regulations on CAMT in advanced stage.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing highlighted expiring TCJA, OECD BEPS – IRS updates rules for requesting PLRs on Section 355 transactions.

A review of the week's major US international tax-related news. In this edition: US tax policy lines being drawn ahead of 2024 election, TCJA 'cliff' – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – OECD releases consolidated GloBE commentary document, revised GloBE examples.

A review of the week's major US international tax-related news. In this edition: IRS waives penalty for failure to pay estimated CAMT – OECD BEPS 2.0 update: what's coming – IESBA announces changes to its Tax Planning and Related Services project that will apply to all tax planning activities.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One Multilateral Convention on Amount A moving forward.

A review of the week's major US international tax-related news. In this edition: US Congress returns from spring recess; no movement on tax bill – IRS releases latest APA report – OECD misses deadline on BEPS Pillar One MLC on Amount A.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.

A review of the week's major US international tax-related news. In this edition: Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.

A review of the week's major US international tax-related news. In this edition: President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.

A review of the week's major US international tax-related news. In this edition: President Biden delivers State of the Union address, offers new tax proposals – US House Ways & Means Tax Subcommittee holds hearing on OECD BEPS Pillar 1 – OECD Secretary-General Tax Report offers insights on BEPS project.

A review of the week's major US international tax-related news. In this edition: US IRS exempts Form 1042 electronic filing in 2024 for US and nonresident withholding agents – IRS will no longer issue significant single issue PLRs – US Senate approves nomination of new IRS Chief Counsel – EY launches new tax podcast series.

A review of the week's major US international tax-related news. In this edition: US Congress to return to session – OECD releases final guidance on BEPS Pillar One Amount B on baseline distributions.

A review of the week's major US international tax-related news. In this edition: US House and Senate recess; focus to turn to approaching government funding deadlines, tax package possible – IRS sending info request letters to US-based subsidiaries of foreign-owned corporations re intercompany transaction pricing – IRS plans to finalize proposed FX regulations by year-end – US signs extension to moratorium agreement on unilateral measures, including DSTs.

A review of the week's major US international tax-related news. In this edition: US House-passed tax package may require Senate Finance Committee markup – Senate begins two-week recess.

A review of the week's major US international tax-related news. In this edition: US House of Representatives passes tax package; Senate action unclear – IRS expects to finalize two sets of Section 367 proposed regulations in first half of 2024 – Senate Finance Committee again approves IRS Chief Counsel nomination – OECD releases first statistics on ICAP.

A review of the week's major US international tax-related news. In this edition: US tax package may get House floor vote week of 29 January, future in the Senate uncertain – US officials offer international tax regulatory update on CAMT, stock buyback excise tax, cloud computing and PTEP rules – OECD releases working paper on global minimum tax and taxation of MNE profit.

A review of the week's major US international tax-related news. In this edition: House and Senate tax writers release $78 billion tax package – Congress passes CR to fund the government – IRS announces cryptocurrency transactions do not have to be reported until regulations issued.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess, government spending and possible tax package on the agenda – IRS to release CAMT package shortly – Treasury official offers US position on BEPS Pillar One – OECD Working Paper addresses global minimum tax and MNE taxation – EY releases 2024 International Tax and Transfer Pricing Survey, respondents say BEPS 2.0 project expands risk of double taxation.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty ceased to have effect – IRS issues interim guidance on basis adjustments re: inbound liquidations or asset reorganizations – IRS updates list of treaty partner countries – IRS broadens scope of possible private letter rulings.

A review of the week's major US international tax-related news. In this edition: OECD/G20 Inclusive Framework releases BEPS 2.0 Pillar Two Administrative Guidance on GloBE rules – OECD announces new BEPS Pillar One MLC timeline – US-Chile income tax treaty enters into force – US Congress adjourns until January 2024 – Congressional JCT releases Bluebook on tax legislation in 117th Congress.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issue FTC guidance addressing BEPS 2.0 Pillar Two GloBE top-up taxes – IRS CAMT regs delayed to 2024, but CAMT Notice released – IRS announces active compliance campaign on CAMT – Stock buyback excise tax guidance still on track for 2023 release – IRS official says PTEP targeted notice coming soon – US government plans to finalize foreign government investment exemption regs in 2024 – IRS working on crypto-asset reporting framework regulations.

A review of the week's major US international tax-related news. In this edition: US Supreme Court holds oral arguments in Moore transition tax case – Congress set to adjourn next week.

A review of the week's major US international tax-related news. In this edition: US-Taiwan tax bill moves forward – OECD to release additional BEPS 2.0 Pillar Two guidance by year-end.

A review of the week's major US international tax-related news. In this edition: Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.

A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

A review of the week's major US international tax-related news. In this edition: US House of Representatives chooses new speaker – US-Chile tax treaty's reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now expected in early 2024 – Cyprus announces Cyprus-US CAA for exchange of CbC reports will be effective for RFYs starting on/after 1 January 2023 – OECD BEPS IF considering Pillar 2 guidance on treatment of deferred tax assets in countries with federal and subnational taxes

A review of the week's major US international tax-related news. In this edition: US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce 'U.S.-Taiwan Expedited Double Tax Relief Act'.

A review of the week's major US international tax-related news. In this edition: OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.

A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada's DST proposal.

A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer "Alternative A" in scoping rules for Amount B in BEPS Pillar One

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and "promoters abusing tax rules on the books."