EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: IRS issues final Base Erosion and Anti-abuse Tax (BEAT) regulations – IRS Notice 2020-69 announces plans to issue regulations on application of Sections 951 and 951A to certain S corporations with accumulated E&P – IRS requests comments on collection of information for competent authority requests – OMB OIRA receives final and proposed FTC regulations for review.

A review of the week's major US international tax-related news. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – US, Swiss competent authorities agree to arbitration procedures under tax treaty.

A review of the week's major US international tax-related news. In this edition: US Senate Republicans reportedly planned limited coronavirus aid package not yet released – IRS Large Business and International division gearing up for major increase in refund claims through Form 1120-X as result of coronavirus aid legislation.

A review of the week's major US international tax-related news. In this edition: US Congress begins August recess, no agreement on coronavirus aid legislation – OMB completes review of final rules on DRD limitation for dividends from certain foreign corporations, proposed rules coordinating certain regulations under Section 245A and Section 951A – Draft Schedules K-2 and K-3 for 2021 tax year IRS partnership Form 1065 guided by need to standardize format, officials say.

A review of the week's major US international tax-related news. In this edition: Congress continues talks over another coronavirus bill, no deal reached – Final BEAT regulations now under OIRA review – IRS may refine Tested Unit Rule under GILTI High-Tax Exclusion rules – UN Tax Committee members issue proposal regarding taxation of digital services income.

A review of the week's major US international tax-related news. In this edition: IRS issues highly-anticipated final and proposed Section 163(j) interest limitation regulations and related guidance – IRS will add compliance resources to review stock-based compensation in cost-sharing arrangements.

A review of the week's major US international tax-related news. In this edition: IRS releases final, proposed GILTI regulations on GILTI high exclusion, subpart F high tax exception – IRS official says proposed PTEP regulations coming before year-end – G20 discusses BEPS 2.0, OECD official comments on timeline.

A review of the week's major US international tax-related news. In this edition: IRS releases new draft partnership forms for 2021, Schedule K-2 and K-3 (Form 1065) – Treasury delivers two international tax-related regulatory projects to OMB's OIRA for review – USTR announces action on France's Digital Services Tax – OECD expects blueprint proposals for BEPS 2.0 Pillar 1 and 2 by October 2020 – OECD releases new corporate tax statistics, including aggregated CbCR data.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final FDII/GILTI regulations – OMB completes review of final regulations on GILTI high-tax exclusion, proposed rules under Section 954(b)(4) high-taxed subpart F income and Section 964 re: E&P of a foreign corporation – IRS seeing more multilateral APA requests – OECD releases model rules for reporting by platform operators regarding sellers in the sharing and gig economy.

A review of the week's major US international tax-related news. In this edition: US Supreme Court declines to hear Altera cost-sharing case – OECD's Saint Amans says BEPS 2.0 Pillar 1 talks are 'still alive'.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: Senate Republicans will not take up next coronavirus stimulus package until end of July – IRS seeks recommendations for 2020-2021 guidance projects – USTR releases USMCA regulations.

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.