EY Cross-Border Taxation Alerts

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.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing on infrastructure highlights differences regarding scope and pay-fors – US Treasury proposes 15% global minimum corporate tax rate – IRS official discusses application of US treaties' derivative benefits test post-Brexit – OECD Multilateral Instrument Conference of the Parties issues interpretative opinion.

A review of the week's major US international tax-related news. In this edition: Biden Administration, Congressional Republicans show some willingness to compromise on infrastructure package – Treasury Green Book detailing President Biden's tax proposals to be released end of May – House Financial Services Committee reports out CbC financial reporting bill, including taxes – IRS modifies accounting method change guidance related to certain foreign corporations.

A review of the week's major US international tax-related news. In this edition: US Congress, Biden Administration focused on infrastructure plans, proposed tax increases – IRS releases updated early drafts of new Schedules K-2 and K-3, for Forms 1065, 1120-S, and 8865, for 2021 tax year – OECD considering framework for elimination of unilateral DSTs post-BEPS 2.0 agreement – OECD cryptoasset project delayed to 2022.

A review of the week's major US international tax-related news. In this edition: US President Joe Biden addresses joint session of Congress, makes case for multi-trillion dollar American Jobs Plan and American Families Plan – Treasury details plan to direct $80 billion to IRS over next 10 years – PTEP proposed regulations now expected to be released in multiple installments, beginning late summer, early fall 2021 – UN releases third edition of UN Transfer Pricing Manual.

A review of the week's major US international tax-related news. In this edition: President Biden to address joint session of Congress; will pitch infrastructure and American Families Plan proposals – Senate Finance Committee Chairman reintroduces Clean Energy for America Act – UN tax committee approves new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden begins outreach on $2.2 trillion American Jobs Plan – IRS issues proposed regs on foreign investment in Opportunity Zone funds – IRS issues FAQs on International Compliance Assurance Program (ICAP) – EY submits comments on EU Public Consultation on digital levy.

A review of the week's major US international tax-related news. In this edition: US Treasury releases report on Biden Administration's Made in America Tax Plan – US Senate Finance Committee Chairman releases framework for international taxation – US presents OECD BEPS 2.0 Pillar One proposal to steering group of Inclusive Framework on BEPS – UN Tax Subcommittee releases final draft of new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden unveils $2 trillion infrastructure plan to be paid for with higher CIT rate, international tax changes – US, Japan reach agreement on tax treaty arbitration process – IRS APMA Program releases annual APA update – US Trade Representative proposes 25% punitive tariffs on Austria, India, Italy, Spain, Turkey, and the UK in response to Digital Services Taxes – OECD initiates consultation on commentary to Article 9 (Associated Enterprises) of OECD Model Tax Treaty. .

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee holds hearing on international taxation – US, 18 other jurisdictions to participate in OECD ICAP – IRS releases practice unit on Section 965 transition tax. .

A review of the week's major US international tax-related news. In this edition: Biden Administration begins to float tax proposals – Senate Finance Committee holds hearings on various aspects of US Tax Code – House, Senate Democrats release international tax bills – IRS official offers international tax guidance update – IRS updates FATCA FAQs.

A review of the week's major US international tax-related news. In this edition: US enacts $1.9 trillion COVID-19 stimulus legislation, including repeal of worldwide interest expense allocation election – IRS Office of Fraud Enforcement initiative to focus on virtual currency – IRS Advance Pricing and Mutual Agreement Program seeing questionable treatment of COVID-related costs – OECD official sees possibility for two simplification measures in BEPS 2.0 Pillar 2 agreement – Platform for Collaboration on Tax issues final version of Toolkit for Tax Treaty Negotiations.

A review of the week's major US international tax-related news. In this edition: US Senate considers $1.9 trillion COVID relief package – US Treasury Secretary takes Pillar 1 safe harbor off table in BEPS 2.0 talks – Murillo named Treasury Deputy Assistant Secretary for International Tax Affairs.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to vote on $1.9 trillion COVID-19 stimulus/relief package on 26 February, action next moves to Senate – US Treasury nominee says goal in BEPS 2.0 talks is to protect US tax revenue and ensure a level playing field.

A review of the week's major US international tax-related news. In this edition: US Congressional tax leader says no consensus on international tax changes – "Platform for Collaboration on Tax" releases toolkit to help developing countries with effective transfer pricing documentation requirements – OECD Forum on Tax Administration releases new handbook for International Compliance Assurance Program (ICAP) – OECD issues 2021 Global Forum Capacity Building Report.

A review of the week's major US international tax-related news. In this edition: US House tax-writing committee approves package representing half of $1.9 trillion COVID relief plan, including international tax provision – Treasury may open project to revive transfer pricing aggregation regulations.

A review of the week's major US international tax-related news. In this edition: US Congress may address international tax regime in 2021, Senate aide says – US, Argentina sign agreement to share CbC reports – OECD holds public consultation on BEPS Action 14 dispute resolution – Final draft of 'Platform for Collaboration on Tax' to be released in Q1 2021.

A review of the week's major US international tax-related news. In this edition: New US Treasury Secretary commits to OECD BEPS 2.0 discussions – OECD releases guidance on COVID-19 related tax treaty issues.

A review of the week's major US international tax-related news. In this edition: President Biden inaugurated as US president; Treasury-designate Janet Yellen confirms tax increases to be delayed – US to re-engage in OECD BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US President-elect Joe Biden announces $1.9 trillion "American Rescue Plan" – Incoming US Senate Finance Committee Chairman Ron Wyden details economic and tax priorities – IRS guidance on Section 864(f) worldwide interest expense allocation a top priority in 2021 – USTR announces investigation findings re Digital Service Taxes in Austria, Spain, and United Kingdom.

A review of the week's major US international tax-related news. In this edition: Democrats control over White House and US Congress has implications for legislation and tax in 2021 – Treasury and IRS release final Section 163(j) business interest expense limitation regulations – US suspends tariff action over Section 301 investigation of France's Digital Services Tax – OECD Pillar One and Two Blueprint public consultation will be held 14-15 January 2021; Inclusive Framework meeting 27-28 January will be public.

A review of the week's major US international tax-related news. In this edition: Democrats control over White House and US Congress has implications for legislation and tax in 2021 – Treasury and IRS release final Section 163(j) business interest expense limitation regulations – US suspends tariff action over Section 301 investigation of France's Digital Services Tax – OECD Pillar One and Two Blueprint public consultation will be held 14-15 January 2021; Inclusive Framework meeting 27-28 January will be public.

A review of the week's major US international tax-related news. In this edition: Congress passes $2.3 trillion omnibus spending and coronavirus stimulus legislation with tax extenders; President Trump calls on Congress to pass new bill – OECD issues COVID-19-related transfer pricing guidance.

A review of the week's major US international tax-related news. In this edition: Treasury sends final Section 163(j) interest expense limitation regulations to OMB for review – Treasury notes progress on new tax treaty with Croatia; resumption of US Senate approvals of bilateral tax treaties expected – IRS will continue to prioritize transfer pricing enforcement in examinations, even if adjustment negated by TCJA provisions – Treasury's FINCEN further extends FBAR filing deadline – OECD BEPS 2.0 Pillar 1 and Pillar 2 comment period ends; BIAC calls for limited BEPS agreement by June 2021 – OECD publishes jurisdiction-specific information on implementation of hard-to-value intangibles approach.

A review of the week's major US international tax-related news. In this edition: IRS APMA Program seeing more COVID-19-related queries regarding APAs – OECD to release COVID-focused TP guidance by end of 2020, beginning 2021 – OECD's FTA announces piloted International Compliance Assurance Program to become full-fledged program in 2021.

A review of the week's major US international tax-related news. In this edition: OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 Blueprints on 14-15 January 2021 – IRS releases final and proposed PFIC regulations – IRS issues final regulations under Sections 245A and 951A that coordinate two sets of anti-abuse rules – IRS LB&I releases internal guidance re: examinations with Section 965 transition tax issues.

A review of the week's major US international tax-related news. In this edition: IRS to release revenue procedure on interaction of GILTI and CFC change of accounting method – US, Mexico renew CA agreement on unilateral APAs for maquiladoras – New IRS guidance on stock-based compensation re cost sharing arrangements coming – PLRs possible on tax treatment of virtual currency transactions – OECD issues consultation document on BEPS Action 14, Making Dispute Resolution More Effective.

A review of the week's major US international tax-related news. In this edition: Joe Biden projected as winner of US Presidential election; tax policy changes examined – IRS updates listing of CAAs for CbC reports.

A review of the week's major US international tax-related news. In this edition: US elections remain undecided – IRS will not release PTEP proposed regulations by year-end – OECD releases report on taxing virtual currencies.

A review of the week's major US international tax-related news. In this edition: IRS announces plans to limit "telescoping" in APA and MAP cases – IRS turning its attention to enforcement, including international partnerships and cost sharing – IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership.

A review of the week's major US international tax-related news. In this edition: IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR end will not result in deemed taxable exchange – IRS will consider amending existing APAs due to effects of COVID-19 pandemic – US government announces US-Hong Kong shipping agreement will terminate effective 1 January 2021.

A review of the week's major US international tax-related news. In this edition: OECD and Inclusive Framework release series of documents on Pillar 1 and 2 of BEPS 2.0 Project, with new mid-2021 completion – G20 Finance Ministers approve progress and timeline – EU agrees to abide by new OECD Inclusive Framework timeline – UN releases new proposed model treaty article and commentary on taxing digital economy.

A review of the week's major US international tax-related news. In this edition: US government releases final partnership withholding regulations under Section 1446 – IRS announces new compliance campaign targeting NRA's unreported US rental income – Inclusive Framework holds meeting on final BEPS 2.0 Pillar 1 and 2 blueprints; release expected 12 October 2020.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final and newly proposed foreign tax credit regulations – US Treasury issues final sourcing regulations on sales of personal property (including inventory) – OECD releases outcomes of third phase of peer reviews on BEPS Action 13.

A review of the week's major US international tax-related news. In this edition: Treasury releases final and proposed regulations on determining CFC status for certain provisions following TCJA repeal of Section 958(b)(4) – Final Treasury regulations under Section 864(c)(8) address US tax consequences of foreign partner's transfer of a partnership interest – OECD will publish final BEPS 2.0 Pillar 1 and 2 blueprints on 12 October 2020.

A review of the week's major US international tax-related news. In this edition: US Congress remains focused on bipartisan negotiations over next coronavirus aid package, extending government funding past 30 September FY-end – Democratic presidential nominee Joe Biden's campaign releases additional tax proposals – IRS Notice 2020-73 announces one year deferral of certain Section 987 final regulations, related rules – G20/OECD Inclusive Framework on BEPS to meet 8-9 October, agreement on Pillar 1 unlikely.

A review of the week's major US international tax-related news. In this edition: Section 163(j) final regulations to be published in Federal Register on 14 September 2020; would be applicable to tax years starting 13 November 2020 – French Finance Minister accuses US of hindering progress in BEPS 2.0 negotiations.