EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee reports out 4 tax protocols to full Senate – US Senate Finance Committee leaders urge Treasury to intensify efforts to convince France not to enact DST – IRS official says proposed GILTI regulations' "high taxed exclusion" prospective date meant to assess election's operation

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee to vote on protocols to US tax treaties with Switzerland, Luxembourg, Spain, and Japan on 25 June 2019 – US releases final GILTI regulations – IRS temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules – Ninth Circuit reverses US Tax Court in Altera v. Commissioner – US, Cyprus negotiating CA agreement to exchange CbC reports

A review of the week's major US international tax-related news: US Senate may hold long-delayed tax treaty hearing – G20 finance ministers approve OECD's digital work plan – DC Circuit affirms Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co. SA – Final GILTI regulations due out before 22 June 2019.

A review of the week's major US international tax-related news: OMB completes review of final and proposed GILTI regulations; Treasury to release before 22 June – US participation exemption guidance clears OMB review – IRS issues proposed regulations on exception from tax for foreign pension fund interests in US real property – IRS LB&I withdraws RAB Share Directive for cost sharing arrangements.

A review of the week's major US international tax-related news: OECD releases digital taxation work program – OMB sets December 2019 target date for release of many high-profile international TCJA final regulations – IRS Commissioner says cryptocurrency guidance coming within 30 days – TIGTA issues report on IRS implementation of Section 965 deemed repatriation tax

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 956 regulations – Treasury official confirms final GILTI regulations by 23 June, BEAT regulations this summer – ECOFIN discusses digital taxation.

A review of the week's major US international tax-related news: US Treasury official warns over global DST proposals – New PTI regulations coming before year-end – IRS issues final FX regulations – IRS releases proposed CFC regulations under Sections 954 and 958 – Final GILTI regulations under OMB review – IRS Internal Legal Memo addresses Section 367(d)

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 1446(f) regulations on W/H for non-publicly traded partnerships – Proposed rules on FIRPTA exception for foreign pension funds expected soon – EU comments on IRC Section 250 proposed regulations, criticizes FDII

A review of the week's major US international tax-related news. In this edition: IRS officials say to expect release of proposed Section 1446(f) regulations, final FATCA regulations, and proposed regulations on repeal of Section 958(b)(4) – India ratifies US-India CbC exchange agreement

Description: A review of the week's major US international tax-related news. In this edition: IRS issues revised US Tax Treaty Table 1 – OECD publishes full version of OECD Model Tax Treaty – UN subcommittee releases report on tax challenges of digitalized economy.

A review of the week's major US international tax-related news. In this edition: US officials offer insights on global digital taxation – IRS LB&I launches 3 new international campaigns

A review of the week's major US international tax-related news. In this edition: US House and Senate tax leaders release digital taxation statement – IRS issues correction to final Section 965 transition tax regulations – Immediate action may be required for foreign-owned US disregarded entities – UN issues draft update to transfer pricing manual for developing countries – EU, UK reach agreement on 6-month Brexit delay

A review of the week's major US international tax-related news. In this edition: US House Republican tax writers voice concern to President Trump about France's DST proposal – US officials comment on future final Section 250 FDII regulations – IRS's new APMA Functional Cost Diagnostic Model may be used in examinations in 'appropriate' cases – GAO issues report on FATCA – OECD Forum on Tax Administration announces ICAP 2.0

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing debates benefits of 2017 TCJA, including international provisions – US, India sign CbC report exchange agreement – IRS releases 2018 APA report – Forum on Tax Administration releases report on tax aspects of sharing and the gig economy at plenary meeting

A review of the week's major US international tax-related news. In this edition: OECD official offers timeline for global digital taxation project – IRS to release proposed previously taxed income (PTI) regulations in late summer or early fall – IRS issues final FATCA regulations – US-India bilateral agreement for exchange of CbC reports announced – OECD releases beneficial ownership toolkit

A review of the week's major US international tax-related news. In this edition: Final GILTI regulations out before summer, but "round 2" will address loss stock basis adjustment rules – EU comments on US Section 59A BEAT – US Treasury official confident of global consensus on digital allocation of taxing rights – OECD official says immediate goal is to finalize and present digital tax work plan to G-20 Finance Ministers and leaders, OECD technical working parties to follow

A review of the week's major US international tax-related news. In this edition: IRS releases Section 250 proposed regulations on determining deduction for FDII and GILTI – IRS announces hearings on proposed regulations on BEAT, hybrid mismatches – IRS APMA releases Functional Cost Diagnostic Model for APA requests – ITS updates FATCA FAQs – EY submits comments on OECD tax consultation on digitalization of the economy

A review of the week's major US international tax-related news. In this edition: OMB completed review of proposed FDII regulations – US government supports efforts to encourage countries to adopt corporate minimum tax – IRS LB&I memo requires transfer pricing issue teams to consult with APMA – IRS requesting comments on final regulations on imposition of Section 6662 accuracy-related penalty for Section 482 adjustments

A review of the week's major US international tax-related news. In this edition: Efforts to update and align transfer pricing regulations and align them with TCJA now underway ─ NYSBA comments on Section 59A proposed Treasury regulations ─ General Court of the European Union annuls Commission's decision on Belgian excess profit rulings ─ OECD releases fifth batch of peer review reports on BEPS Action 14

A review of the week's major US international tax-related news. In this edition: OECD opens public consultation on addressing tax challenges from digitalization of the economy – US Treasury official responds to OECD digitalization proposals – Finalization of US international tax regulations may pass June 2019 deadline

A review of the week's major US international tax-related news. In this edition: US Treasury official responds to OECD policy note on digital taxation – IRS will not relax anti-corporate inversion rules – Code Section 965 final regulations published in Federal Register; clarification on due date for filing transfer agreements

A review of the week's major US international tax-related news. In this edition: OECD issues major Policy Note relating to work on 'Addressing the Tax Challenges of the Digitalisation of the Economy' – OECD released Harmful Tax Practices – 2018 Progress Report on Preferential Regimes – US Senate tax leaders voice concern over European DST proposals – Congressional Democrats may use technical corrections as leverage for tax incentives

A review of the week's major US international tax-related news. In this edition: OECD BIAC releases 11 principles to guide tax reform for digital economy – OECD may address more than digital business activity, potentially impacting other IP-intensive business models

A review of the week's major US international tax-related news. In this edition: IRS releases final Section 965 transition tax regulations – US Senate Finance Committee's first priority is tax extenders legislation

New House Ways and Means Committee Chairman offers hints re: tax agenda – IRS issues final Section 163(j) Form and Instructions

A review of the week's major US international tax-related news. In this edition: US Congress fails to enact year-end tax legislation, Federal government enters into partial shutdown – Outgoing House Ways and Means Committee Chairman releases discussion draft of Tax Technical and Clerical Corrections Act – Status of OMB review of TCJA regulations during government shutdown unclear

A review of the week's major US international tax-related news. In this edition: US House approves tax bill; Senate action unlikely -- Congressional Joint Committee on Taxation releases general explanation of the Tax Cuts and Jobs Act (Blue Book) – IRS issues proposed regulations on Sections 245A(e) and 267A – IRS issues proposed regulations under Section 864(c)(8) on tax treatment of foreign partners gains on sale of a US partnership interest – IRS Notice 2019-01 announces future regulations re: foreign corporations with PTEP -- OMB received proposed Section 250 regulations for review

A review of the week's major US international tax-related news. In this edition: US House tax leader releases modified year-end tax package -- IRS releases proposed Section 59A Base Erosion and Anti-Abuse Tax (BEAT) regulations – IRS issues Section 965 transition tax FAQs -- OMB completes review of proposed TCJA Section 864c()(8) regulations; release imminent – IRS issues proposed FATCA, withholding regulations – US Treasury issues another FBAR extension -- OECD will release major digital tax update end of January 2019

A review of the week's major US international tax-related news. In this edition: US Republican efforts to move tax legislation stall in House – US Treasury sends final Section 965 transition tax regulations, proposed regulations under Section 864(c)(8) to OMB for review – ECOFIN fails to reach agreement on proposed EU Digital Services Tax; US House tax leader weighs in

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on computing interest expense limitation under Code Section 163(j) – IRS releases complex foreign tax credit regulations – Congressional Republicans advance year-end tax legislation in lame-duck session

A review of the week's major US international tax-related news. In this edition: US, Singapore signed TIEA and new FATCA Model I IGA – OECD released update to 2017 Progress report on Preferential Tax Regimes – OECD Inclusive Framework on BEPS released substantial activities requirement for "no or only nominal tax" jurisdictions -- OECD now gathering input on implementation of BEPS Action 14 minimum standard for review of seventh batch of jurisdictions

A review of the week's major US international tax-related news. In this edition: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance – US House tax leader eying 70-80 TCJA technical corrections for lame-duck legislation

A review of the week's major US international tax-related news. In this edition: US mid-term election will affect tax in Congressional lame-duck and 2019 – Treasury sends TCJA's BEAT and FTC proposed regulations to OMB for review -- EU Ministers meet on proposed Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS recently issued Section 163(j) draft Form 8990, draft instructions for BEAT Form 8991 – IRS LB&I issues 3 more international tax compliance campaigns -- US House tax leader issues warning about proposed UK DST, other unilateral measures – Netherlands announces intent to repeal Decree re: US-Netherlands tax treaty relation to hybrid entities

A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existing tax treaty

A review of the week's major US international tax-related news. In this edition: Proposed FTC and Section 163(j) regulations release to OMB Office of Regulatory Affairs imminent -- Proposed PTI regulations unlikely to be released as complete package by year-end – 2018 IRS deadline for QI, Withholding Foreign Partnership and Withholding Foreign Trust applications is 16 November 2018 – OECD making progress on digital tax framework

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA's FDII later this month -- US official says OECD making good progress on long-term digital tax package

A review of the week's major US international tax-related news. In this edition: IRS Notice 2018-78 provides welcome amendments to Section 965 proposed regulations – IRS proposed regulations on GILTI to be published in Federal Register on 10 October 2018; 60-day comment period begins

A review of the week's major US international tax-related news. In this edition: US House moves forward with 'tax reform 2.0' – GILTI regulations to be finalized by June 2019 – IRS restructuring Advance Pricing and Mutual Agreement program.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations removing IRC Section 385 debt/equity documentation regulations – IRS releases draft Form 8991 on new Section 59A BEAT provision -- IRS Notice 2018-72 delays effective date of Section 871(m) dividend equivalent payments by two years – US House tax leader urges IRS to issue virtual currency guidance – OECD issues additional CbCR guidance.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 951A GILTI regulations – IRS issues guidance on REIT Section 951A, foreign currency income inclusions – House tax writing committee approves Tax Reform 2.0

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-election session – House tax-writing committee to move Tax Reform 2.0 week of 10 September

A review of the week's major US international tax-related news. In this edition: OECD released fourth round of BEPS Action 14 peer reports on improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Treasury sends TCJA's global intangible low taxed income (GILTI) regulations to OMB for review – IRS issues draft forms for GILTI, foreign derived intangible income (FDII) provisions

A review of the week's major US international tax-related news. In this edition: Second Circuit Court of Appeals affirms district court decision in Trusted Media Brands, Inc. v. USA -- Eighth Circuit Court of Appeals vacates 2017 Tax Court order in Medtronic, Inc. v. Comm'r

A review of the week's major US international tax-related news. In this edition:US Ninth Circuit withdraws opinion in Altera – US Tax Court rules partnership's Section 1446 withholding tax liability is a partnership item – Congressional Republicans urge President Trump to nominate OECD ambassador

IRS releases Section 965 proposed regulations on TCJA repatriation transition tax -- Ninth Circuit reverses Tax Court in Altera cost sharing case – DC Circuit overturns Tax Court in Good Fortune Shipping, rules Section 883 '"bearer share" regulations invalid -- IRS FATCA certification portal is now live

A review of the week's major US international tax-related news. In this edition: US House tax leader releases Tax Reform 2.0 framework – OMB completes review of Proposed Section 965 transition regulations – OECD Secretary-General Report to G20 Finance Ministers and Central Bank Governors on BEPS, tax transparency released

A review of the week's major US international tax-related news. In this edition: US House Republicans to release outline of proposals for "phrase 2" tax reform bill week of 23 July 2018 – OMB review of proposed Section 965 repatriation transition regulations pending -- Treasury official offers insights into coming TCJA international tax guidance – IRS official say countries reviewing how to use CbC reporting data

A review of the week's major US international tax-related news. In this edition: US international-focused tax technical corrections bill expected following November elections – Tax Reform 2.0 may fine-tune new international provisions – IRS issues final anti-corporate inversion regulations – IRS LB&I announces two new compliance campaigns on repatriation of foreign earnings -- IRS LB&I issues transfer pricing, automatic exchange of information memos – US Treasury Inspector General for Tax Administration releases negative FATCA report – OECD issues discussion draft on financial transactions under BEPS Actions 8-10