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 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.

A review of the week's major US international tax-related news. In this edition: US Senate approves FY 2017 budget resolution with tax reform reconciliation instructions – Treasury Secretary, House Speaker expect tax reform in 2017 – Administration official says tax reform details negotiable, except 20% CIT rate and middle-class relief

A review of the week's major US international tax-related news. In this edition:US House Republicans remain committed to enacting tax reform in 2017 – Foreign minimum tax may be necessary to adopt US territorial tax system – Bipartisan group of House tax writers call for partial withdrawal of FIRPTA Notice 2007-55

A review of the week's major US international tax-related news. In this edition:US House and Senate Republicans move forward on reconciliation instructions for passage of US tax reform -- Senate Finance Committee holds hearing on international tax reform – US Treasury issues report on 8 tax regulations identified as burdensome, including debt/equity and FX regulations – IRS Notice 2017-57 announces deferral of applicability date of final Section 987 FX regulations.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans release tax reform framework -- IRS issues draft update of APA template – OECD releases first peer review reports on minimum standards on Action 14, improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Senate Budget Committee agrees on FY '18 Budget Resolution; implications for tax reform – "Big 6" tax reform consensus document released next week – US Treasury to publicly release report on "significant tax regulations" in September – IRS official upbeat on countries' implementation of OECD dispute resolution recommendations; concern over established transfer pricing principles.

A review of the week's major US international tax-related news. In this edition: US Tax Reform "consensus document" set for release week of 25 September – President Trump pushes for 15% CIT rate – Treasury/IRS Guidance Plan to be released in fall – Deadline for Treasury to report recommendations on "significant tax regulations" 18 September.

A review of the week's major US international tax-related news. In this edition: Congress approves bill to provide hurricane relief funding – President Trump calls for Democrats to join him in support of an "American Model" of tax reform – OECD releases further guidance on CbC Reporting – Lafayette G. "Chip" Harter III appointed deputy assistant secretary for international tax affairs for the US Treasury

A review of the week's major US international tax-related news. In this edition: Renewed push for US tax reform after Labor Day – Trump Administration expects Congress to take lead on reform legislation.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans to release details on tax reform in "short order" – "Big 6" negotiators looking for revenue for tax reform.

A review of the week's major US international tax-related news. In this edition: White House tax negotiators and congressional leaders plan to release document outlining framework for tax reform -- Congressional tax staffers to focus on anti-base erosion rules now that proposed border adjustment tax will not be adopted.

A review of the week's major US international tax-related news. In this edition: US corporate tax rate may settle in low to mid-20% range – IRS extends transition period for applying parts of Section 871(m) rules – IRS now accepting Form 8975, Country-by-Country Report and Schedules A.

A review of the week's major US international tax-related news. In this edition: Trump Administration outlines new strategy for enacting US tax reform – Kautter confirmed as new Treasury Assistant Secretary (Tax Policy) -- Tax Court holds US parent's CFCs held US property under Section 956 as result of intercompany transactions -- Tax Court rules IRS abused its discretion in cancelling two APAs – US concludes Competent Authority Arrangements for exchange of CbC reports with Australia and Estonia.

A review of the week's major US international tax-related news. In this edition: House border adjustability proposal no longer under consideration for US tax reform – Few repeal recommendations expected in final report on 8-Obama-era tax regulations deemed significant -- US signs 5 more Competent Authority Arrangements for automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House Budget Committee approves FY 2018 budget resolution with reconciliation instructions for US tax reform – White House official says "Big 6" and their staffs making headway on US tax reform – US Senate Finance Committee advances nomination of David Kautter for Treasury Assistant Secretary for Tax Policy -- US Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments; broad implications and possible refund claims -- Deadline approaching for certain MNCs to request suspension of MAP-related deadline under Mexico-US income tax treaty – OECD released updated version of Guidance on the Implementation of Country-by-Country Reporting.