Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US’ OECD contribution.

A review of the week's major US international tax-related news. In this edition: IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary testifies before Senate Finance Committee on FY ‘24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira’s hyperinflationary status has US tax consequences.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

A review of the week's major US international tax-related news. In this edition: IRS will issue initial guidance on how far back to apply basis adjustments to arrive at “opening” books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US shareholder for Section 951(a)(2)(B) purposes.

A review of the week's major US international tax-related news. In this edition: IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

A review of the week's major US international tax-related news. In this edition: President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, ‘billionaire surtax’ – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs, competent authority assistance.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.

A review of the week's major US international tax-related news. In this edition: Rep. Kevin McCarthy new House Speaker, Rep. Joshua Smith named chairman of House Ways and Means Committee – IRS CAMT guidance addresses questions, leaves open issues.

A review of the week's major US international tax-related news. In this edition: IRS issues interim guidance on application of new corporate alternative minimum tax – IRS releases interim guidance on excise tax on certain corporate stock buybacks – IRS releases final regulations on FIRPTA tax exception for qualified foreign pension funds and qualified controlled entities.

A review of the week's major US international tax-related news. In this edition: US Congress passes $1.7 trillion spending bill; no Tax Title – Treasury plans guidance on CAMT and stock buyback excise tax by year-end – IRS announces it will issue proposed regulations amending final Section 1446(f) final withholding regulations for PTPs – Treasury official says GILTI will need to be reformed – Congressional Republican lawmakers voice concerns over BEPS Pillar Two Undertaxed Profits Rule – OECD issues (i) consultation document on Pillar One MLI re: DSTs; (ii) consultation document on Pillar Two GloBE information return; (iii) consultation document on Pillar Two tax certainty for GloBE rules; and (iv) guidance on Pillar Two safe harbors and penalty relief.

A review of the week's major US international tax-related news. In this edition: US Congress passes temporary stopgap spending measure to facilitate omnibus bill negotiation; Tax Title uncertain – IRS releases Rev. Ruling 2022-43 with final qualified intermediary   withholding agreement – IRS issues proposed regulations on single-entity treatment of consolidated groups for purposes of Section 951 – FinCEN further extends FBAR filing deadline – FinCEN issues proposed regulations on beneficial ownership – OECD releases consultation document on Amount B of BEPS 2.0 Pillar One – EU adopts Directive on global minimum tax.

A review of the week's major US international tax-related news. In this edition: US Congress grapples with government funding in lame duck, will impact tax package options – US, Croatia sign tax treaty – OECD releases consultation document on design elements of BEPS Pillar One Amount B re: simplification of transfer pricing rules.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame duck session; business tax measures could be included in omnibus spending bill – IRS Corporate Alternative Minimum Tax guidance possible before year-end.

A review of the week's major US international tax-related news. In this edition: IRS pivoting to cryptocurrency, opens digital asset project office – IRS drafting questions on cryptocurrency, digital assets for corporate and partnership returns.

A review of the week's major US international tax-related news. In this edition: Republicans take House, Democrats hold Senate; lame-duck legislation remains uncertain – IRS issues highly anticipated foreign tax credit proposed regulations – IRS proposed regulations under Section 367(d) will be released early next year – IRS considering use of economic substance in transfer pricing audits, even with TP documentation.

A review of the week's major US international tax-related news. In this edition: US congressional lame duck tax legislation unclear amid midterm election uncertainty – Proposed foreign tax credit regulations coming soon, limited CAMT guidance this year – IRS releases 2022-2023 Priority Guidance Plan – Congressional ranking Republicans urge reversal of decision to terminate US-Hungary tax treaty – Biden Administration nominates new IRS Commissioner.