EY Cross-Border Taxation Alerts

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

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee Chairman Kevin Brady discusses tax reform 2.0 – IRS to issue new proposed rules this year for controlled foreign corporations' previously taxed income – proposed regulations withdrawing the Section 385 debt-equity documentation rules officially "pending review" – OECD Multilateral Convention to enter into force on 1 July 2018 – OECD announces publication of stakeholder comments it received in response to request for public comments on revisions to OECD Transfer Pricing Guidelines – OECD launches comparable tax revenue database

A review of the week's major US international tax-related news. In this edition:US Supreme Court rules in South Dakota v. Wayfair; major impact on all companies with sales to US, including foreign-based companies – US House Budget Committee approves FY 2019 budget resolution -- OECD releases two reports, on Hard-to-Value Intangibles and application of Transactional Profit Split Method

A review of the week's major US international tax-related news. In this edition: US congressional tax leader wants 'phase 2' reform bill released before August recess – IRS announces plan to delay application of Section 987 FX regulations for additional year -- IRS will give US W/H agents 60 days following issuance of IDR to cure accounts – IRS soon to release final FATCA regulations for FFI 'sponsors' – IRS will issue two sets of guidance for TCJA's new Section 1446(f)

A review of the week's major US international tax-related news. In this edition: IRS announces Section 965 transition late-payment penalty and filing relief -- US officials offer more insights on upcoming international TCJA guidance – US taxpayers with high-risk transfer pricing and PE issues that participate in OECD's ICAP may face IRS exam – IRS to deploy portal for FATCA certifications by late July, early August

A review of the week's major US international tax-related news. In this edition: White House official confirms 'phase 2' tax reform discussions with Congressional tax writers – US, Croatia considering tax treaty – OECD issues first peer report on BEPS Action 13 -- EU Council adopts Directive on new mandatory reporting of cross-border reportable arrangements.

A review of the week's major US international tax-related news. In this edition: US House Republicans, Trump Administration discussing framework for 'phase two' tax reform -- Final anti-corporate inversion regulations may be out in June -- IRS LB&I reviewing ongoing compliance campaigns in light of TCJA -- Updated UN Model Tax Treaty released.

A review of the week's major US international tax-related news. In this edition: Acting IRS Commissioner talks at May 2018 ABA Section of Taxation meeting about guidance projects implementing the TCJA – Treasury and IRS officials also address several tax reform related issues at the Meeting – IRS official reports IRS considering whether potential regulations under Section 267A should prevent the denial of deductions when a hybrid instrument or entity is not the cause of preferential treatment of relevant income – US District Court dismisses taxpayer's suit against IRS in transfer pricing dispute.

A review of the week's major US international tax-related news. In this edition: US OMB Office of Regulatory Affairs provides insight into scope and release of TCJA international tax regulations – US House Ways and Means Committee to hold hearings on economic effects of tax reform – IRS announces plans to issue regulations expanding exception to Section 956(c) US property -- OECD considering revising Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: US House tax chairman floats "Tax Reform 2.0" – TCJA Technical Corrections unlikely in 2018 – IRS comments on interpreting new Section 163(j) -- OECD may up release consensus blueprint on digital economy to 2019.

A review of the week's major US international tax-related news. In this edition: Treasury and IRS officials offer TCJA international tax insights -- Final FATCA regulations close to release – Tax professor to advise on OMB/Treasury tax regulation agreement – US, Indonesia release MOU on CbC reporting – US and Costa Rica sign new TIEA.

A review of the week's major US international tax-related news. In this edition: European Union continues deliberations on elements of US tax reform – OECD Tax Director comments on US tax reform

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:US takes issue with EU digital tax proposals – EU to consider putting US on tax haven blacklist – US IRS issues FATCA publications

A review of the week's major US international tax-related news. In this edition:EU, OECD address digital taxation -- US strongly opposes taxes on digital economy – IRS to issue consolidated group guidance re: new Sections 965 and 163(j) in early April – IRS considering GILTI in context of US foreign tax credit regime – OECD releases new report on PE attribution of profits – OECD MLI will enter into force 1 July 2018

A review of the week's major US international tax-related news. In this edition: Congressional Republicans, Trump Administration mull "phase 2" tax reform – Joint Committee on Taxation working on tax reform "bluebook," identifying technical corrections – IRS released FAQs on Section 965 repatriation transition tax – Final anti-corporate inversion regulations completed -- OECD released Interim Report on tax challenges from digitalization.

A review of the week's major US international tax-related news. In this edition: IRS expands "no TIN" list to include foreign jurisdictions that offer TINS; Australia added to list – Treasury considering carving-out long-term bank loans from "cash or cash equivalents" in Section 965 transition tax -- EU requests OECD Forum on Harmful Tax Practices conduct "fast track" review of certain US tax reform provisions.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee Chairman expects series of small, technical corrections bills to TCJA -- House Ways and Means Tax Policy Subcommittee will hold hearing on tax extenders on 14 March – Senior Treasury tax official resigns.

A review of the week's major US international tax-related news. In this edition: US Treasury officials offer updates on TCJA international guidance -- IRS LB&I issued guidelines for delinquent Forms 1120-F, waiver requests – EU surveying European multinationals re: US tax reform.

A review of the week's major US international tax-related news. In this edition: US government issues more repatriation transition guidance in Rev. Proc. 2018-17 – Treasury officials offer insights on future international TCJA guidance – US to defend TCJA's FDII provision as WTO-compliant – IRS taking leadership role in OECD's International Compliance Assurance Program -- OECD released more BEPS Action 13 CbC reporting guidance

Updated US Treasury/IRS 2017 - 2018 Priority Guidance Plan issued with TCJA projects – Treasury to delay effective date of final Section 987 branch currency regulations to 2020 – US to begin tax treaty negotiations with Armenia

A review of the week's major US international tax-related news. In this edition: US Treasury addresses tax guidance for TCJA – Joint Committee on Taxation reviewing issues for TCJA technical corrections, but no date – 'Off-year' Blue Book on TCJA possible.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-13 – Treasury close to determining fate of Section 385 debt/equity regulations -- Treasury Secretary attempts to ease European concerns regarding US tax reform legislation.

A review of the week's major US international tax-related news. In this edition: US technical tax corrections bill on hold for now – IRS LB&I issues series of internal transfer pricing directives – IRS says taxpayers can elect mark-to-market method of accounting in recent Section 988 proposed regulations.

A review of the week's major US international tax-related news. In this edition: US Treasury grants further extension for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2018-07 on new transition tax – IRS suspends W/H obligations under new Section 1446(f) for certain publicly traded partnership interests – FASB to issue additional guidance on ASC 740, Income Taxes, re: provisions in Tax Cuts and Jobs Act -- US Tax Court rules 6-year limitations period in Section 6501 only applies for tax years to which Section 6038D foreign financial asset reporting requirement effective.

A review of the week's major US international tax-related news. In this edition: US tax reform has tax accounting implications; SEC offers financial statement reporting relief – EU voices concern over US tax reform's international provisions.

A review of the week's major US international tax-related news. In this edition: US Congress passes landmark tax reform legislation, President Trump signs bill into law – House Republican tax leader says more US tax legislation coming – IRS issues proposed FX regulations – US, Spain sign CAA to exchange CbC Reports – IRS to appeal Grecian Magnesite Mining to DC Circuit Court of Appeals.

A review of the week's major US international tax-related news. In this edition: US tax reform bill finalized; Congress to vote week of 18 December -- US, France sign joint statement on exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House, Senate vote to go to conference committee to reconcile final tax reform bill – Transition period floated for tax reform international provisions – Repeal of ACA mandate may be included in final tax reform bill – Treasury official expects considerable "sub-regulatory guidance" after enactment of tax reform.

A review of the week's major US international tax-related news. In this edition: US Senate poised to pass US tax reform bill -- IRS may not complete bilateral CAAs by year-end for exchange of CbC reports -- IRS issues proposed regulations on international issues related to new partnership audit regime -- IRS rules GRA term fixed as of date of initial transfer -- US to appeal IRS violated APA regarding anti-inversion regulations.

A review of the week's major US international tax-related news. In this edition: US Senate to consider Finance Committee tax reform bill after Thanksgiving holiday – Congressional Republicans, Trump Administration officials aim to enact tax reform by year-end.

A review of the week's major US international tax-related news. In this edition:US House of Representatives approves comprehensive tax reform bill – US Senate Finance Committee reports out tax bill; consideration on Senate floor expected week of 27 November.

A review of the week's major US international tax-related news. In this edition:Congress moving forward on competing tax reform bills; action expected -- IRS announces 3 new international tax compliance campaigns -- OECD published updated Transfer Pricing Country Profiles.

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee releases comprehensive tax reform bill -- Treasury considering clarifications to 'F' reorganization regulations -- US official suggests non-delta-one transaction rules in Section 871(m) dividend equivalent regulations may not take effect.

A review of the week's major US international tax-related news. In this edition:House approves Senate-passed FY 2018 budget resolution; Ways and Means Committee tax reform bill set for release 1 November, legislative markup to begin 6 November – Treasury official says Section 385 debt/equity regulations 'overly burdensome' and will be substantially amended – David Kautter, current Treasury Assistant Secretary for Tax Policy, also named Acting IRS Commissioner.