EY Cross-Border Taxation Alerts

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.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee to begin markup the week of 6 September re: Budget Resolution – IRS articulates five-factor test in determining income inclusion of reimbursement payments – US, France sign joint statement on spontaneous exchange of CbC reports for FYs beginning 2020 and 2021.

A review of the week's major US international tax-related news. In this edition: US House passes FY 2022 budget resolution on path to trillion-dollar reconciliation bill; infrastructure vote no later than 27 September – Senate Finance Committee Chairman, committee members provide details on international tax framework proposals – IRS extends date for W/H on certain transfers, distributions related to publicly traded partnership interests to 1 January 2023.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to convene to consider FY 2021 Budget Resolution – US, Germany agree to share CbC reporting information.

A review of the week's major US international tax-related news. In this edition: US Senate passes $1.2 trillion infrastructure bill, $3.5 trillion budget resolution with reconciliation instructions – Senate Finance Committee Chairman releases financial derivatives overhaul proposal – IRS official says new financial entities campaign will be broad.

A review of the week's major US international tax-related news. In this edition: US Senate moves toward passage of $1.2 trillion bipartisan infrastructure bill – OECD confirms US government's intention to abolish Foreign Derived Intangible Income regime.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan Senate negotiators reach agreement on $1.2 trillion infrastructure package; Senate Democrats have votes to move on budget resolution – US, UK competent authorities sign agreements re: NAFTA and derivative benefits in treaty LOB – Treasury official offers international tax regulatory update – OECD releases sixth batch of peer reports on BEPS Action 14 minimum standard on dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Senate Majority leader misses initial infrastructure legislation and budget resolution deadlines – IRS addresses cost sharing agreements and inclusion of stock-based compensation costs – OECD plans to complete work on BEPS 2.0 multilateral convention and model domestic legislation by close of 2021, early 2022.

A review of the week's major US international tax-related news. In this edition: Senate Budget Committee Democrats agree on $3.5 trillion budget resolution, paving way for "human infrastructure" paid for with tax increases – Bipartisan $1 trillion infrastructure negotiators given 21 July deadline – Biden Administration wants global minimum tax in budget reconciliation package; Pillar Two elements on slower track.

A review of the week's major US international tax-related news. In this edition: OECD announces conceptual agreement in BEPS 2.0 project – IRS issues early draft instructions for amended Schedules K-2 and K-3 for 2021 Forms 1065, 1120-S, and 8865.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan senators agree to infrastructure deal – OECD publishes Model Reporting Rules for Digital Platforms: International Exchange Framework.

A review of the week's major US international tax-related news. In this edition: More US Senators publicly support $1.2 trillion bipartisan infrastructure compromise – House passes corporate disclosure package requiring country-by-country tax reporting for multinationals.

A review of the week's major US international tax-related news. In this edition: Bipartisan US Senate group proposes $1.2 trillion infrastructure package – G7 Finance Ministers express strong support for ongoing work on OECD BEPS 2.0 project – Biden Administration's proposed 15% minimum tax on book earnings could include public disclosure of book-tax differences – IRS announces deferral of applicability date of BEAT qualified derivative payment reporting – Treasury discusses information reporting proposals regarding virtual currencies.

A review of the week's major US international tax-related news. In this edition: US Treasury 'Green Book' details Biden Administration's international tax proposals – President Biden, Senate Republicans continue infrastructure talks – USTR announces and suspends tariffs over digital services taxes – G-7 officials begin meeting; expected to pledge support for BEPS 2.0 talks.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing discusses US international tax proposals – Biden Administration, Senate Republicans trading infrastructure proposals.