Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US-Taiwan tax bill moves forward – OECD to release additional BEPS 2.0 Pillar Two guidance by year-end.

A review of the week's major US international tax-related news. In this edition: Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.

A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

A review of the week's major US international tax-related news. In this edition: US House of Representatives chooses new speaker – US-Chile tax treaty’s reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now expected in early 2024 – Cyprus announces Cyprus-US CAA for exchange of CbC reports will be effective for RFYs starting on/after 1 January 2023 – OECD BEPS IF considering Pillar 2 guidance on treatment of deferred tax assets in countries with federal and subnational taxes

A review of the week's major US international tax-related news. In this edition: US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce ‘U.S.-Taiwan Expedited Double Tax Relief Act’.

A review of the week's major US international tax-related news. In this edition: OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.

A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada’s DST proposal.

A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer “Alternative A” in scoping rules for Amount B in BEPS Pillar One

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and “promoters abusing tax rules on the books.” 

A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

A review of the week's major US international tax-related news. In this edition: US Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.

A review of the week's major US international tax-related news. In this edition: IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

A review of the week's major US international tax-related news. In this edition: Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

A review of the week's major US international tax-related news. In this edition: Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

A review of the week's major US international tax-related news. In this edition: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS 2.0 Pillars One and Two technical documents – House Ways and Means Tax Subcommittee hearing on BEPS sees Republicans criticize Biden Administration’s policy – IRS PTEP proposed regs on track for release later this year.