EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: No action on President Biden's Build Back Better agenda as Congress pivots to other legislative priorities – Treasury developing interim guidance on cryptocurrency reporting .

A review of the week's major US international tax-related news. In this edition: Build Back Better Act faces uncertain path – Treasury and IRS release final foreign tax credit regulations – IRS finalizes rules addressing the tax consequences of the elimination of LIBOR and other interbank offered rates .

A review of the week's major US international tax-related news. In this edition: Senator Joe Manchin will not support Build Back Better Act; Majority Leader will bring forward 'modified' version of bill in new year – OECD releases Model Rules on the Pillar Two Global Minimum Tax .

A review of the week's major US international tax-related news. In this edition: US Senate will not take up Build Back America Act in 2021 – Updated Senate Finance Committee's title of the Build Back Better Act retains House's international tax proposals, but with major technical changes – Final foreign tax credit regulations clear OMB, return for final Treasury review – OMB reviewing final regula...

A review of the week's major US international tax-related news. In this edition: US Senate Democratic BBBA meetings with Parliamentarian concluded; bipartisan "Byrd bath" meetings begin next week – Senate Foreign Relations Committee Republicans urge vote on proposed 2010 US-Chile tax treaty – Treasury's FinCEN published proposed regulations on beneficial ownership .

A review of the week's major US international tax-related news. In this edition: US Congress turns to Build Back Better reconciliation bill after recess – Final foreign tax credit regulations release before year-end -- US, India announce digital tax, trade action compromise – Technical aspects of model rules for OECD BEPS Pillar 2 complete; further Pillars' consultation planned.

A review of the week's major US international tax-related news. In this edition: US, Turkey announce digital tax, trade action compromise – OECD committed to BEPS Pillars in effect by end of 2023 – US Congress in recess; Senate expected to take up House-passed Build Back Better Act after Thanksgiving break.

A review of the week's major US international tax-related news. In this edition: President Biden signs infrastructure legislation – House passes Build Back Better Act budget reconciliation bill, Senate consideration after Thanksgiving holiday – IRS releases new tool to support US withholding agents compliance with reporting, withholding re IRS Form 1042-S – IRS requests comments on Rev. Proc. 2015...

A review of the week's major US international tax-related news. In this edition: President Biden to sign infrastructure legislation next week with crypto provisions; House Speaker wants reconciliation vote week of 15 November – Final foreign tax credit regulations expected before year-end – Proposed PTEP regulations moving forward.

A review of the week's major US international tax-related news. In this edition: US House poised to pass Build Back Better Act budget reconciliation bill, infrastructure legislation – IRS ILM concludes extended six-year assessment period under Section 6501(e)(1)(c) applies to entire tax liability, not just omitted subpart F and/or GILTI items.

A review of the week's major US international tax-related news. In this edition: New $1.75 trillion US budget reconciliation framework and legislative text released; tax items not fully settled.

A review of the week's major US international tax-related news. In this edition: Negotiations continue in congress to reach agreement on House reconciliation bill – Treasury releases joint statement with several countries on DST Agreement – IRS issues commodity derivatives private letter ruling – Platform for Collaboration on Tax enhances support to countries in the area of domestic resource mobil...

A review of the week's major US international tax-related news. In this edition: Debate continues over size and scope of US budget reconciliation bill – G-20 Finance Ministers endorse BEPS 2.0 Pillar One and Pillar Two agreement – US officials discuss implementation of BEPS 2.0 – US to defer by one additional year applicability date of final Section 987 FX regulations, certain related final regula...

A review of the week's major US international tax-related news. In this edition: Inclusive Framework on BEPS announces agreement on Two Pillar solution – US Congressional Democrats' dispute over size of Build Back Better budget reconciliation bill continues – OECD publishes two MLI opinions.

A review of the week's major US international tax-related news. In this edition: US Congress grapples over infrastructure, budget reconciliation legislation – G7 Finance Ministers make progress on BEPS 2.0 issues in lead up to October 2021 meetings -- IRS lists jurisdictions with which it has information exchange for reporting certain deposit interest paid.

A review of the week's major US international tax-related news. In this edition: White House, House and Senate Democrats discussing path forward on budget reconciliation bill – IRS APMA director warns taxpayers against unilateral relief.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee clears major tax bill to partially fund Build Back Better Act; includes major changes to US international tax rules – IRS seeing $1 billion MAP cases, LB&I official says.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee begins budget reconciliation markup – Treasury pushes for 21 percent minimum corporate tax on foreign earnings – Senate Finance Committee Chairman releases draft partnership tax legislation – Treasury official offers update on coming final foreign tax credit regulations – IRS releases...

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee to begin markup the week of 6 September re: Budget Resolution – IRS articulates five-factor test in determining income inclusion of reimbursement payments – US, France sign joint statement on spontaneous exchange of CbC reports for FYs beginning 2020 and 2021.

A review of the week's major US international tax-related news. In this edition: US House passes FY 2022 budget resolution on path to trillion-dollar reconciliation bill; infrastructure vote no later than 27 September – Senate Finance Committee Chairman, committee members provide details on international tax framework proposals – IRS extends date for W/H on certain transfers, distributions related...

A review of the week's major US international tax-related news. In this edition: US House of Representatives to convene to consider FY 2021 Budget Resolution – US, Germany agree to share CbC reporting information.

A review of the week's major US international tax-related news. In this edition: US Senate passes $1.2 trillion infrastructure bill, $3.5 trillion budget resolution with reconciliation instructions – Senate Finance Committee Chairman releases financial derivatives overhaul proposal – IRS official says new financial entities campaign will be broad.

A review of the week's major US international tax-related news. In this edition: US Senate moves toward passage of $1.2 trillion bipartisan infrastructure bill – OECD confirms US government's intention to abolish Foreign Derived Intangible Income regime.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan Senate negotiators reach agreement on $1.2 trillion infrastructure package; Senate Democrats have votes to move on budget resolution – US, UK competent authorities sign agreements re: NAFTA and derivative benefits in treaty LOB – Treasury official offers international tax regulatory update – OE...

A review of the week's major US international tax-related news. In this edition: US Senate Majority leader misses initial infrastructure legislation and budget resolution deadlines – IRS addresses cost sharing agreements and inclusion of stock-based compensation costs –  OECD plans to complete work on BEPS 2.0 multilateral convention and model domestic legislation by close of 2021, early 2022.