EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

A review of the week's major US international tax-related news. In this edition: US Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.

A review of the week's major US international tax-related news. In this edition: IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

A review of the week's major US international tax-related news. In this edition: Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

A review of the week's major US international tax-related news. In this edition: Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

A review of the week's major US international tax-related news. In this edition: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS 2.0 Pillars One and Two technical documents – House Ways and Means Tax Subcommittee hearing on BEPS sees Republicans criticize Biden Administration's policy – IRS PTEP proposed regs on track for release later this year.

A review of the week's major US international tax-related news. In this edition: OECD releases outcome statement on BEPS 2.0 Pillars One and Two progress – US Congress considering action on a US-Taiwan tax agreement – US senators reissue crypto-assets legislative proposal, request more information – Joint Committee on Taxation issues digital asset report.

A review of the week's major US international tax-related news. In this edition: US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.

A review of the week's major US international tax-related news. In this edition: US Senate approves US-Chile income tax treaty – Congressional Joint Committee on Taxation releases revenue analysis of BEPS Pillar Two global minimum tax – BEPS Pillar One and Pillar Two developments expected in coming weeks.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee approves three separate tax packages – Proposed US-Chile income tax treaty may have final US Senate vote as early as 21 June – OMB's OIRA will no longer review Treasury tax regulations – OECD officials comment on BEPS Pillars One and Two.

A review of the week's major US international tax-related news. In this edition: Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.

A review of the week's major US international tax-related news. In this edition: US Congress passes debt ceiling legislation – US House Ways and Means Committee Republicans introduce legislation targeting OECD BEPS 2.0 Pillar Two Undertaxed Profits Rule – US Senate Foreign Relations Committee reports out proposed US-Chile income tax treaty – US House members introduce resolution calling for legislation to prevent US-Taiwan double taxation.

A review of the week's major US international tax-related news. In this edition: US House Republicans to introduce anti-BEPS Pillar Two legislation – G-7 Finance Ministers welcome OECD progress report, reiterate commitment to BEPS Pillars One and Two – IRS to hire additional transfer pricing and competent authority staff, will expand CAP, APA and pre-filing programs.

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.