EY Cross-Border Taxation Alerts

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.

A review of the week's major US international tax-related news. In this edition: US House leaders hope to pass "China competitiveness" bill before 4 July recess – Senate introduces bill to disallow foreign tax credits (FTCs) for taxes paid to Russia or Belarus – Treasury, IRS considering changes to FTC regulations – IRS proposed Section 1256 regulations on FX contracts set for release in coming weeks, Section 987 rules to follow – IRS issues GLAM on allocation and apportionment of deferred compensation expense for FDII deductions, reverses prior guidance – Treasury, OECD officials offer BEPS 2.0 insights.

A review of the week's major US international tax-related news. In this edition: Little action on budget reconciliation as US Congress focuses on 'China competitiveness' legislation – Treasury official reveals government working on "Killer B" cross-border triangular reorg regs, Section 367(d) rules involving transferred IP repatriated to US.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary calls on Congress to pass BEPS-like minimum corporate tax – Treasury officials comment on BEPS 2.0 – IRS publishes changes to QI withholding agreement rules – IRS unclear on scope of financial transaction transfer pricing regulation project – US House Ways and Means Committee members request delay to implementation of final FTC regulations – First-ever US-Croatia income tax treaty under US State Department review.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington to budget reconciliation uncertainty; Senator Manchin offers high-level clarity – OECD holds public consultation on Implementation Framework for BEPS 2.0 Pillar Two GloBE Rules – OECD releases public comments on Draft Model Rules for Domestic Legislation on Scope under Pillar One.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington; Democrats may make one last attempt at reconciliation legislation – Biden Administration supports both BEAT repeal and replacement with UTPR and BBB's BEAT reforms.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary says BEPS 2.0 will help global economies recover from COVID-19 pandemic, Ukraine crisis – IRS releases new Schedules K-2, K-3 FAQs – US Senate Foreign Relations Committee issues report on proposed US-Chile tax treaty.

A review of the week's major US international tax-related news. In this edition: Prospects for post-Build Back Better Act reconciliation bill uncertain – Senate bill would deny US FTCs for Russian taxes paid – OECD announces public consultation on draft model rules on scope of Amount A in BEPS 2.0 Pillar One.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY2023 budget with international tax proposals – US Senate Foreign Relations Committee approves US-Chile income tax treaty – OECD public consultation on crypto-asset reporting framework expected by end of May.

A review of the week's major US international tax-related news. In this edition: President Biden to release FY 2023 budget on 28 March – Sen. Manchin revives pared-down budget reconciliation talks – Final US FTC regulations will be amended to reflect BEPS 2.0 Pillar One and Pillar Two – Senate Foreign Relations Committee to take up US-Chile tax treaty, US-Croatia treaty talks in final stages – OECD initiates public consultation on crypto-asset reporting framework, amendments to CRS.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – OECD releases BEPS 2.0 Pillar Two commentary – US Senate Finance Committee Chairman supports tax sanctions for Russia and Belarus – IRS official recommends all taxpayers seeking PLRs should avail of new fast-track process.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – Treasury official confirms previously-taxed earnings and profits regulations coming in latter half of 2022 – IRS official says partial US FTC may only be available on foreign withholding on IP royalties in certain instances.

A review of the week's major US international tax-related news. In this edition: President Biden presents first State of the Union address; lists provisions but does not mention Build Back Better – Sen. Manchin says he could support limited reconciliation package focused on taxes, climate change and deficit reduction – Senate Democrats eye US-Russia tax treaty in response to Ukraine crisis.

A review of the week's major US international tax-related news. In this edition: OECD officials reconfirm ambitious BEPS 2.0 timeline; provide further details – OECD is finalizing tax reporting framework for cryptoassets.

A review of the week's major US international tax-related news. In this edition: US Senate mulls anti-inflation measures – IRS releases FAQs on transition relief for certain domestic partnerships and S corporations completing new Schedules K-2 and K-3 – Treasury official comments on future proposed regulations on cryptocurrency reporting requirements for brokers – OECD official concedes BEPS 2.0 Pillar One draft rules complexity – Republican Senate Finance Committee members concerned over BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US inflation report may affect size and scope of future social spending, climate and tax bill – Increasing signs Congress may act on year-end 2021 tax changes.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin reiterates need for wholly new spending and tax bill; Congress faces full agenda – OECD announces first wave of consultations on the BEPS 2.0 Pillar One rules, releases consultation document – OECD official reinforces BEPS 2.0 timeline.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin confirms Build Back Better discussions back on – Concern over double taxation if US GILITI unamended – Republican tax writers warn BEPS Pillars require congressional action – Treasury releases final regulations on treatment of domestic partnerships under Section 958, proposed PFIC regulations – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework.

A review of the week's major US international tax-related news. In this edition: President Biden favors breaking up Build Back Better into smaller bills – OECD BEPS 2.0 Pillar Two model rules commentary expected in early February – OECD releases 2022 Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: No action on President Biden's Build Back Better agenda as Congress pivots to other legislative priorities – Treasury developing interim guidance on cryptocurrency reporting.

A review of the week's major US international tax-related news. In this edition: Build Back Better Act faces uncertain path – Treasury and IRS release final foreign tax credit regulations – IRS finalizes rules addressing the tax consequences of the elimination of LIBOR and other interbank offered rates.

A review of the week's major US international tax-related news. In this edition: Senator Joe Manchin will not support Build Back Better Act; Majority Leader will bring forward 'modified' version of bill in new year – OECD releases Model Rules on the Pillar Two Global Minimum Tax.

A review of the week's major US international tax-related news. In this edition: US Senate will not take up Build Back America Act in 2021 – Updated Senate Finance Committee's title of the Build Back Better Act retains House's international tax proposals, but with major technical changes – Final foreign tax credit regulations clear OMB, return for final Treasury review – OMB reviewing final regulations on interbank offered rates (IBORS) – OECD to release Pillar Two Global Anti-Base Erosion Model Rules on 20 December.

A review of the week's major US international tax-related news. In this edition: US Senate Democratic BBBA meetings with Parliamentarian concluded; bipartisan "Byrd bath" meetings begin next week – Senate Foreign Relations Committee Republicans urge vote on proposed 2010 US-Chile tax treaty – Treasury's FinCEN published proposed regulations on beneficial ownership.

A review of the week's major US international tax-related news. In this edition: US Congress turns to Build Back Better reconciliation bill after recess – Final foreign tax credit regulations release before year-end -- US, India announce digital tax, trade action compromise – Technical aspects of model rules for OECD BEPS Pillar 2 complete; further Pillars' consultation planned.

A review of the week's major US international tax-related news. In this edition: US, Turkey announce digital tax, trade action compromise – OECD committed to BEPS Pillars in effect by end of 2023 – US Congress in recess; Senate expected to take up House-passed Build Back Better Act after Thanksgiving break.

A review of the week's major US international tax-related news. In this edition: President Biden signs infrastructure legislation – House passes Build Back Better Act budget reconciliation bill, Senate consideration after Thanksgiving holiday – IRS releases new tool to support US withholding agents compliance with reporting, withholding re IRS Form 1042-S – IRS requests comments on Rev. Proc. 2015-41 regarding APAs and MAP applications and compliance.

A review of the week's major US international tax-related news. In this edition: President Biden to sign infrastructure legislation next week with crypto provisions; House Speaker wants reconciliation vote week of 15 November – Final foreign tax credit regulations expected before year-end – Proposed PTEP regulations moving forward.

A review of the week's major US international tax-related news. In this edition: US House poised to pass Build Back Better Act budget reconciliation bill, infrastructure legislation – IRS ILM concludes extended six-year assessment period under Section 6501(e)(1)(c) applies to entire tax liability, not just omitted subpart F and/or GILTI items.

A review of the week's major US international tax-related news. In this edition: New $1.75 trillion US budget reconciliation framework and legislative text released; tax items not fully settled.

A review of the week's major US international tax-related news. In this edition: Negotiations continue in congress to reach agreement on House reconciliation bill – Treasury releases joint statement with several countries on DST Agreement – IRS issues commodity derivatives private letter ruling – Platform for Collaboration on Tax enhances support to countries in the area of domestic resource mobilization during the COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Debate continues over size and scope of US budget reconciliation bill – G-20 Finance Ministers endorse BEPS 2.0 Pillar One and Pillar Two agreement – US officials discuss implementation of BEPS 2.0 – US to defer by one additional year applicability date of final Section 987 FX regulations, certain related final regulations – Cyprus clarifies Cyprus-US CAA for exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: Inclusive Framework on BEPS announces agreement on Two Pillar solution – US Congressional Democrats' dispute over size of Build Back Better budget reconciliation bill continues – OECD publishes two MLI opinions.

A review of the week's major US international tax-related news. In this edition: US Congress grapples over infrastructure, budget reconciliation legislation – G7 Finance Ministers make progress on BEPS 2.0 issues in lead up to October 2021 meetings -- IRS lists jurisdictions with which it has information exchange for reporting certain deposit interest paid.

A review of the week's major US international tax-related news. In this edition: White House, House and Senate Democrats discussing path forward on budget reconciliation bill – IRS APMA director warns taxpayers against unilateral relief.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee clears major tax bill to partially fund Build Back Better Act; includes major changes to US international tax rules – IRS seeing $1 billion MAP cases, LB&I official says.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee begins budget reconciliation markup – Treasury pushes for 21 percent minimum corporate tax on foreign earnings – Senate Finance Committee Chairman releases draft partnership tax legislation – Treasury official offers update on coming final foreign tax credit regulations – IRS releases 2021–2022 Priority Guidance Plan – IRS allows taxpayer to reverse "gap period" transaction through late CTB election.