EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: OECD official offers insights on BEPS Pillar One and Pillar Two – US Senate Foreign Relations Committee may act on proposed US-Chile tax treaty – IRS official clarifies coming PTEP regulations in regard to partnerships.

A review of the week's major US international tax-related news. In this edition: President Biden, congressional leaders in debt ceiling talks, but no breakthroughs yet – US Senate Finance Committee holds hearing on cross-border pharma manufacturers and US international tax policy – US government officials discuss CAMT guidance, another notice coming – New US-Israel tax treaty in the works – US, Swiss tax protocol negotiations progressing.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed regulations on IP repatriation subject to Section 367(d) – Bipartisan US senators introduce bill to authorize negotiations with Taiwan to conclude tax agreement – US, Norway conducting tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: US House passes debt ceiling, spending bill – Treasury says no decision on interim CAMT guidance – IRS updates crypto notice – OECD to release BEPS Pillar Two qualified domestic minimum top-up tax safe harbor by summer.

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans introduce debt limit, spending bill – SEC Chairman defends agency's authority over cryptocurrency products.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess; will need to address debt ceiling and spending – IRS issues proposed rules on micro-captive transactions as listed transactions.

A review of the week's major US international tax-related news. In this edition: IRS will provide transition period for documentation requirements for FTC "single-country exception" – US Tax Court rules IRS lacks authority to assess penalties under Section 6038(b) – US, Germany sign competent authority arrangement on automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US' OECD contribution.

A review of the week's major US international tax-related news. In this edition: IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary testifies before Senate Finance Committee on FY '24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira's hyperinflationary status has US tax consequences.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

A review of the week's major US international tax-related news. In this edition: IRS will issue initial guidance on how far back to apply basis adjustments to arrive at "opening" books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US shareholder for Section 951(a)(2)(B) purposes.

A review of the week's major US international tax-related news. In this edition: IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

A review of the week's major US international tax-related news. In this edition: President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, 'billionaire surtax' – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs, competent authority assistance.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.

A review of the week's major US international tax-related news. In this edition: Rep. Kevin McCarthy new House Speaker, Rep. Joshua Smith named chairman of House Ways and Means Committee – IRS CAMT guidance addresses questions, leaves open issues.

A review of the week's major US international tax-related news. In this edition: IRS issues interim guidance on application of new corporate alternative minimum tax – IRS releases interim guidance on excise tax on certain corporate stock buybacks – IRS releases final regulations on FIRPTA tax exception for qualified foreign pension funds and qualified controlled entities.

A review of the week's major US international tax-related news. In this edition: US Congress passes $1.7 trillion spending bill; no Tax Title – Treasury plans guidance on CAMT and stock buyback excise tax by year-end – IRS announces it will issue proposed regulations amending final Section 1446(f) final withholding regulations for PTPs – Treasury official says GILTI will need to be reformed – Congressional Republican lawmakers voice concerns over BEPS Pillar Two Undertaxed Profits Rule – OECD issues (i) consultation document on Pillar One MLI re: DSTs; (ii) consultation document on Pillar Two GloBE information return; (iii) consultation document on Pillar Two tax certainty for GloBE rules; and (iv) guidance on Pillar Two safe harbors and penalty relief.

A review of the week's major US international tax-related news. In this edition: US Congress passes temporary stopgap spending measure to facilitate omnibus bill negotiation; Tax Title uncertain – IRS releases Rev. Ruling 2022-43 with final qualified intermediary withholding agreement – IRS issues proposed regulations on single-entity treatment of consolidated groups for purposes of Section 951 – FinCEN further extends FBAR filing deadline – FinCEN issues proposed regulations on beneficial ownership – OECD releases consultation document on Amount B of BEPS 2.0 Pillar One – EU adopts Directive on global minimum tax.

A review of the week's major US international tax-related news. In this edition: US Congress grapples with government funding in lame duck, will impact tax package options – US, Croatia sign tax treaty – OECD releases consultation document on design elements of BEPS Pillar One Amount B re: simplification of transfer pricing rules.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame duck session; business tax measures could be included in omnibus spending bill – IRS Corporate Alternative Minimum Tax guidance possible before year-end.

A review of the week's major US international tax-related news. In this edition: IRS pivoting to cryptocurrency, opens digital asset project office – IRS drafting questions on cryptocurrency, digital assets for corporate and partnership returns.

A review of the week's major US international tax-related news. In this edition: Republicans take House, Democrats hold Senate; lame-duck legislation remains uncertain – IRS issues highly anticipated foreign tax credit proposed regulations – IRS proposed regulations under Section 367(d) will be released early next year – IRS considering use of economic substance in transfer pricing audits, even with TP documentation.

A review of the week's major US international tax-related news. In this edition: US congressional lame duck tax legislation unclear amid midterm election uncertainty – Proposed foreign tax credit regulations coming soon, limited CAMT guidance this year – IRS releases 2022-2023 Priority Guidance Plan – Congressional ranking Republicans urge reversal of decision to terminate US-Hungary tax treaty – Biden Administration nominates new IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Treasury warns there may be little guidance re new corporate minimum tax and stock buyback tax before effective date – No transition period or delay in implementation date for final Section 1446(f) withholding regulations – IRS expects more penalties in transfer pricing cases – House Ways and Means Committee Republicans request Treasury retain all documents, communications re OECD BEPS 2.0 Pillar One Agreement.

A review of the week's major US international tax-related news. In this edition: US Treasury working on 'prophylactic' measures to address new tax regimes in the context of future tax treaties – US, Croatia to sign tax treaty before year-end – Treasury official expects proposed crypto regulations release in 2022 – OECD wants broad acceptance of its Crypto Asset Reporting Framework.

A review of the week's major US international tax-related news. In this edition: IRS proposed foreign tax credit regulations 'weeks away' – 2006 proposed PTEP regs officially withdrawn, new regs in first half of 2023 – IRS official offers update on new corporate alternative minimum tax – IRS plans to reconsider APA revenue procedure guidance in light of recent Eaton Corporation decision.

A review of the week's major US international tax-related news. In this edition: OECD releases new global tax transparency framework for crypto-assets, amendments to Common Reporting Standard – IRS to request Sponsoring Entities cancel their FATCA agreement if they fail to meet Sponsoring Entity requirements.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework on BEPS releases new consultation on Pillar One Amount A, other BEPS related documents – OECD will release amendments to crypto-asset reporting framework, Common Reporting Standard on 10 October.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund federal government, recesses until after midterm elections – EY comments on Inflation Reduction Act's CAMT in M&A context – FinCEN issues final beneficial ownership rule – OECD's FTA issues bilateral APA manual.

A review of the week's major US international tax-related news. In this edition: House Republican leadership set to release "Commitment to America" platform – IRS provides guidance on applying noncompulsory payment rules in FTC regs to amended tax decrees between MNEs and Puerto Rico tax authority – IRS officials offer updates on international issues and regulations.

A review of the week's major US international tax-related news. In this edition: US Congress focused on CR to extend government funding beyond 30 September; post-midterm year-end bill could address tax – House Republicans poised to release "Commitment to America" November election platform – OECD holds public consultation on Progress Report on BEPS Pillar One Amount A.

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-midterm election session – Treasury official offers international regulatory update; PTEP regs coming in Q1 2023 – US tax treaty negotiations with Switzerland, Israel to begin; pending treaties being updated – 6th Circuit rules IRS bears burden of proof to cancel APAs – OECD considering two permanent safe harbors re BEPS 2.0 Pillar Two global minimum tax rules – OECD's Pascal Saint Amans to step down.

A review of the week's major US international tax-related news. In this edition: IRS Notice 2022-36 penalty relief applies to certain international tax information returns – OECD releases public comments on Progress Report on Amount A of BEPS Pillar One – EY concludes Amount A of Pillar One will result in a few mature market jurisdictions gaining additional taxing rights, but most others receiving little benefit.

A review of the week's major US international tax-related news. In this edition: IRS to delay effective date for aspects of Section 871(m) regulations, further extend transition relief – IRS extends deadline for unfiled 2019 and 2020 returns, penalty relief for certain 2019 and 2020 returns – US Tax Court increases Medtronic royalty rate under unspecified TP method.

A review of the week's major US international tax-related news. In this edition: President Biden signs Inflation Reduction Act of 2022 into law; includes new 15% corporate alternative minimum tax – Inflation Reduction Act includes unprecedented energy and climate provisions – Stock buyback provision in Inflation Reduction Act may have broader implications – IRS funding in Inflation Reduction Act may increase scrutiny of transfer pricing cases – Treasury and IRS to extend applicability date of 2016 final Section 987 FX regulations additional year.

A review of the week's major US international tax-related news. In this edition: Senate approves Inflation Reduction Act of 2022 – President Biden signs CHIPS and Science Act.

A review of the week's major US international tax-related news. In this edition: US Senate Democrats reach agreement on health, climate and tax budget reconciliation bill; moves to Senate floor 6 August – House Ways and Means Committee Republicans introduce resolution to compel Treasury to produce documents showing effects of BEPS 2.0 Pillar One rules.

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740 billion climate/energy, health and tax reconciliation bill – Congress passes $280 billion CHIPS and Science Act; goes to President for signature – IRS makes substantive changes to final US foreign tax credit regulations.

A review of the week's major US international tax-related news. In this edition: US budget reconciliation legislation uncertainty continues – Treasury confirms termination of US-Hungary tax treaty.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington following 4 July recess; Sen. Manchin will not support climate measures, tax increases in budget reconciliation following US inflation report – IRS releases proposed FX regulations – US plans to terminate US-Hungary tax treaty – OECD releases Progress Report on Amount A of Pillar One.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats continue to negotiate slimmed-down budget reconciliation bill – OECD officials provide BEPS 2.0 update at annual tax conference – US officials discuss BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin meet again to discuss budget reconciliation – US Supreme Court accepts FBAR case for review – IRS plans to expand transfer pricing audit coverage.

A review of the week's major US international tax-related news. In this edition: President Biden expresses confidence budget reconciliation bill will pass Congress; meetings held – Congressional Republicans propose anti-inflationary measures, including tax cuts – Republican House Ways and Means Committee members ask Treasury to delay final foreign tax credit regulations – OECD official urges 'first-movers' on BEPS 2.0 Pillar Two.

A review of the week's major US international tax-related news. In this edition: US Sen. Manchin says no deal yet on limited budget reconciliation bill – Treasury Secretary comments on BEPS Pillar One – Treasury official offers insights on computing CFCs' minimum taxes in BEPS Pillar Two – Treasury Secretary says no delay in final foreign tax credit regulations – 28 CFOs comment on final foreign tax credit rules.

A review of the week's major US international tax-related news. In this edition: Congress returns from Memorial Day holiday to budget reconciliation uncertainty – Support Ukraine Through Our Tax Code Act introduced in the House – US government supports excluding reinsurance and asset management from the BEPS 2.0 Pillar One – OECD initiates public consultation on BEPS Pillar One tax certainty – OECD Secretary General predicts BEPS 2.0 practical implementation from 2024 onwards.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats move "soft deadline" for BBB action to August recess – US Treasury offers insights to future FTC guidance – OECD officials discuss BEPS 2.0 progress.