EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: USTR launches investigations of new or proposed Digital Services Taxes in 10 jurisdictions – IRS lists US info exchange agreements re: certain deposit interest paid to residents of those jurisdictions – OECD announces release of Toolkit on the Taxation of Offshore Indirect Transfers.

A review of the week's major US international tax-related news. In this edition: US Treasury sends final FDII, GILTI deduction regulations to OMB for review – OECD official says governments refocusing on BEPS.

A review of the week's major US international tax-related news. In this edition: US government considers incentives to lure manufacturing back to the United States – Treasury announces USMCA to replace NAFTA references in US tax treaties – OECD holds virtual public consultation on 2020 review of CbC reporting.

A review of the week's major US international tax-related news. In this edition: US House set to pass HEROES Act stimulus legislation; Senate will not take up bill – IRS issues final Section 385 debt/equity regulations – IRS modifies MAP, APA filing procedures to reflect COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats poised to release fourth coronavirus relief package – IRS provides limited DCL and Form 8858 / 8865 relief for temporary activities resulting from coronavirus travel disruptions – OECD postpones July 2020 IF BEPS 2.0 meeting to October.

A review of the week's major US international tax-related news. In this edition: US Congress set to reconvene in May; timing of next COVID-19 stimulus bill uncertain – IRS updates FATCA FAQs, 1 July certification due date extended 15 December 2020.

A review of the week's major US international tax-related news. In this edition: President Trump signs $484 billion interim COVID-19 relief bill into law – IRS issues FAQs on interaction of CARES Act NOL carryback and Section 965 transition tax – IRS releases guidance for foreign businesses and nonresident aliens affected by COVID-19 travel disruptions – IRS issues FAQs on best practices and common mistakes in preparing transfer pricing documentation.

A review of the week's major US international tax-related news. In this edition: IRS grants relief for real estate, farming businesses to withdraw or make late Section 163(j)(7) elections, based on CARES Act – LB&I outlines compliance activities either postponed or allowed through 15 July 2020 – OECD BEPS 2.0 IF Steering Group agrees to continue project on current timelines.

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called 'Midco' listed transactions – IRS issues 2019 APA annual report.

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called 'Midco' listed transactions – IRS issues 2019 APA annual report.

A review of the week's major US international tax-related news. In this edition: Coronavirus Aid, Relief, and Economic Security Act (CARES Act) has international tax implications for multinationals – IRS issues interim guidance on offers in compromise re: Section 965 transition tax.

A review of the week's major US international tax-related news. In this edition: US Congress enacts $2t Coronavirus Aid, Relief, and Economic Security (CARES) Act stimulus package – IRS posts FAQs on extension of certain filing and payment deadlines to 15 July 2020 – IRS announces FATCA Report (Form 8966) filings due 31 March extended to 15 July 2020 – IRS unveils new People First Initiative to address COVID-19, temporarily suspends key compliance programs.

A review of the week's major US international tax-related news. In this edition: US government responds to COVID-19 pandemic, enacts Families First Coronavirus Response Act – US Senate Republicans release draft $1 trillion COVID-19 bill – US announces tax return filing, payment extensions – IRS issues final foreign tax credit regulations for covered asset acquisitions – OECD to go 'full steam' on BEPS 2.0 project – EY's Global Tax Policy Center releases COVID-19 Stimulus Tracker.

A review of the week's major US international tax-related news. In this edition: IRS expects fewer corporate taxpayer participants in compliance assurance program due to strict eligibility requirements – TIGTA releases report on discrepancy findings that tax withholding required by FIRPTA is not being identified or addressed – Number of TCJA tax regulations at the OMB's OIRA continues to grow – UK issues 2020 Budget confirming implementation of a 2% DST on revenues earned from 1 April 2020.

A review of the week's major US international tax-related news. In this edition: IRS will not issue regulations aligning transfer pricing rules to TCJA changes re: definition of intangible property before 2021 – House Republicans urge Treasury Secretary to withdraw portion of IRS Notice 2007-55 relating to REIT liquidating distributions – UK government will 'consider' US opposition to DST in lead up to trade talks.

A review of the week's major US international tax-related news. In this edition: OMB completes review of final regulations under Sections 245(e) and 267A – G20 endorse BEPS 2.0 "Outline of the Architecture of a Unified Approach on Pillar One" as basis for negotiations.

A review of the week's major US international tax-related news. In this edition: US official says major TCJA international tax guidance on track for release by October 2020; provides unofficial timeline – Altera files writ of certiorari with US Supreme Court in cost sharing case – OECD expected to reach agreement on core BEPS 2.0 Pillar 1 and 2 principles by close of 2020 – OECD issues Consultation Document on "sharing" and "gig" economy.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary confirms US-France DST de-escalation agreement – Treasury Secretary defends TCJA international guidance at congressional hearing – Senate Finance Committee Democrats introduce GILTI amendment – OECD issues final TP report on financial transactions – OECD releases CbCR consultation document – OECD reports BEPS 2.0 Pillar 1 and 2 would raise additional $100b global CIT annually.

A review of the week's major US international tax-related news. In this edition: IRS has no plans to issue additional Section 965 transition tax guidance – IRS will accept PLR requests for determining BEAT base erosion payment – OMB sends final Section 163(j) business interest deduction limitation regulations back to Treasury – Singapore announces US-Singapore TIEA in force 5 March 2020.

A review of the week's major US international tax-related news. In this edition: US supports OECD Pillar 1 proposals as 'safe harbor' – IRS rules target's capitalized transaction costs do not create separate and distinct intangible asset – UK leaves EU on 31 January 2020, begins transition period – OECD Inclusive Framework on BEPS meets on Pillar 1 and 2 proposals.

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations for contributions of appreciated property by US persons to partnerships with related foreign partners – IRS's recently announced Section 965 repatriation relief is case-by-case – US officials comment on pending Section 245A DRD and Section 163(j) interest limitation guidance – US, France trade war over French DST on hold through 2020; France suspends collection of DST.

A review of the week's major US international tax-related news. In this edition: IRS may revise broad definition of interest in pending final Section 163(j) regulations – IRS may amend FMV requirement in proposed regulations for phaseout of LIBOR, variant interest rates – IRS will consider cryptocurrency PLRs – France will not eliminate DST notwithstanding US retaliatory tariffs.

A review of the week's major US international tax-related news. In this edition: USTR holds hearing on tariffs in response to France's DST – TCJA final regulations on Section 163(j) and hybrid dividends and payments pending OMB review.

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on W/H and reporting tax re US source income paid to foreign persons – IRS proposed regulations modify rules for sourcing income from sales of inventory within/outside US – FinCen further extends FBAR filing deadline – US hopeful pending US tax treaties with Chile, Hungary, and Poland will be approved in 2020 – OECD release additional CbC reporting guidance.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation with CFC look-through provision – IRS issues final Section 871(m) regulations on dividend equivalent payments, extends transition relief – US Treasury sends final Section 163(j) regulations and final Section 267A hybrid mismatch regulations to OMB for review – OECD and US Treasury officials comment on BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: OECD holds public consultation on GloBE Pillar 2 proposals – OECD to release economic modeling of Pillar 1 and Pillar 2 proposals in early 2020.

A review of the week's major US international tax-related news. In this edition: IRS releases final BEAT regulations – IRS issues final and proposed FTC regulations – IRS Notice 2019-65 defers applicability date of final Section 987 regulations and related rules by one additional year – US has 'serious concerns' over OECD BEPS 2.0 Pillar 1 – USTR proposes punitive duties on French goods over France's new DST.

A review of the week's major US international tax-related news. In this edition: Participants at OECD public consultation on BEPS Pillar One identify existing global transfer pricing system as needing change – US government holds release of foreign tax credit, BEAT regulations – Spanish Supreme Court rules US RIC entitled to Spanish dividend WHT refund.

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on ownership attribution rules for CFC purposes – OMB fall 2019 agenda includes new IRS final reg project on rules for domestic shareholders' accounting method changes for foreign corporations – OECD holds public consultation on BEPS Pillar One project.

A review of the week's major US international tax-related news. In this edition: Release of IRS foreign tax credit, BEAT regulations imminent – US Treasury officials offer international tax guidance timeline – Ninth Circuit Court of Appeals denies request for en banc rehearing in Altera v. Commissioner – EY submits comment letter on OECD Pillar 1 consultation document. .

A review of the week's major US international tax-related news. In this edition: IRS announces new Section 965 transition tax campaign – IRS warns against using transfer pricing to avoid BEAT – OECD releases Pillar 2 Consultative Document – OECD issues more CbCR guidance – OECD announces new Analytical Database on MNEs and affiliates – OECD releases additional guidance on spontaneous information exchange by no, low-tax jurisdictions.

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 385 regulations removing minimum documentation requirements; announces it will modify "distribution regulations" – OMB completes review of final and proposed FTC regulations – Congressional JCT releases Blue Book explanation for tax legislation enacted in 115th Congress – Draft IRS partnership form and instructions reflect new Section 864(c)(8) – UK receives Brexit extension until 31 January 2020; general election 12 December.

A review of the week's major US international tax-related news. Update on US international guidance at OMB OIRA – IRS to continue scrutiny of virtual currency transactions – IRS concludes Section 952(c) election to include excludible insurance income in subpart F income of CFCs' US shareholder is obsolete – G20 expresses support for OECD's two-pillar approach.

A review of the week's major US international tax-related news. US Congress considers spending bill as vehicle for tax extenders, TCJA technical corrections – UK, EU reach agreement on new Brexit deal – OECD hopes to finalize digital tax proposal details in January, political agreement by June 2020.

A review of the week's major US international tax-related news. In this edition: OECD releases Pillar One Consultation Document on digitalization of the economy – IRS Notice 2019-58 addresses final, temporary, and proposed Section 385 debt/equity regulations – IRS issues guidance on tax treatment of cryptocurrency transactions – Foreign tax credit and Section 59A BEAT regulations pending OMB OIRA review.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations on TCJA repeal of Section 958(b)(4) for determining CFC status – IRS releases Rev. Proc. 2019-40 on repeal of Section 958(b)(4); details safe harbors.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry into force of tax protocols with Luxembourg and Switzerland – Bipartisan US Senate lawmakers in early discussions on tax extenders legislation; CFC look-through expires at year-end – European General Court rules Netherlands did not grant illegal State aid to Starbucks – OECD holds first Tax Certainty Day; 2018 MAP statistics released

A review of the week's major US international tax-related news. In this edition: US Treasury sends final and proposed Section 59A BEAT regulations to OMB for review – IRS reconsidering Form 1120-F nonfilers compliance campaign following TIGTA review – OECD official says Pillar 1 and Pillar 2 proposals will incorporate tax certainty as a core component.

A review of the week's major US international tax-related news. In this edition: US Congress: Update on technical corrections, tax extenders, new tax treaties – International tax-related TCJA fall guidance – Protocol to US-Luxembourg tax treaty enters into force – US, France in talks over Digital Services Tax; US may take action against other nations' unilateral digital taxes.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry-into-force dates for protocols to US-Japan and US-Span tax treaties.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry-into-force dates for protocols to US-Japan and US-Span tax treaties.

A review of the week's major US international tax-related news. In this edition: French President comments on new Digital Services Tax – IRS lists jurisdictions with reporting requirements for interest and OID paid to certain NRAs

A review of the week's major US international tax-related news. In this edition: US Ninth Circuit affirms Tax Court's Amazon transfer pricing decision – IRS will permit domestic partnerships, S corporations to apply rules from proposed GILTI regulations for tax years ending before 22 June 2019 – USTR holds hearing on France's Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on cloud-based, digital transactions – Revised version of IRS Publication 5188 on reporting FATCA data released – OECD issues BEPS Action 14 Stage 2 peer review reports on dispute resolution; includes US.

A review of the week's major US international tax-related news. In this edition: IRS formally withdraws "Altera" CSA memo in light of Ninth Circuit decision – President Trump signs instruments of ratification to tax protocols amending treaties with Luxembourg, Switzerland, Japan, and Spain

A review of the week's major US international tax-related news. In this edition: US threatens retaliation against France's new DST – IRS begins sending virtual currency letters to taxpayers

A review of the week's major US international tax-related news. In this edition: Altera Corp. files petition for rehearing challenge of 2003 cost sharing regs – IRS publishes final regs relating to the allocation of creditable foreign tax expenditures by a partnership – UK's Boris Johnson to succeed Theresa May as Prime Minister; UK publishes draft legislation and consultation paper on EU MDR – OECD updates peer review of preferential tax regimes

A review of the week's major US international tax-related news. In this edition: US Senate approves four protocols updating the existing bilateral tax treaties with Luxembourg, Switzerland, Japan and Spain – IRS releases additional information to assist with filing and payment obligations for Section 965 transition tax on untaxed foreign earnings – G7 Finance Ministers support OECD two-pillar project to develop new rules for taxing multinational businesses – 2019 UN tax treaty negotiation manual updated to reflect changes in 2017 UN Model Treaty – APMA's functional cost diagnostic model intended to help officials with complex cases

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations