EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on cloud-based, digital transactions – Revised version of IRS Publication 5188 on reporting FATCA data released – OECD issues BEPS Action 14 Stage 2 peer review reports on dispute resolution; includes US.

A review of the week's major US international tax-related news. In this edition: IRS formally withdraws "Altera" CSA memo in light of Ninth Circuit decision – President Trump signs instruments of ratification to tax protocols amending treaties with Luxembourg, Switzerland, Japan, and Spain

A review of the week's major US international tax-related news. In this edition: US threatens retaliation against France's new DST – IRS begins sending virtual currency letters to taxpayers

A review of the week's major US international tax-related news. In this edition: Altera Corp. files petition for rehearing challenge of 2003 cost sharing regs – IRS publishes final regs relating to the allocation of creditable foreign tax expenditures by a partnership – UK's Boris Johnson to succeed Theresa May as Prime Minister; UK publishes draft legislation and consultation paper on EU MDR – OE...

A review of the week's major US international tax-related news. In this edition: US Senate approves four protocols updating the existing bilateral tax treaties with Luxembourg, Switzerland, Japan and Spain – IRS releases additional information to assist with filing and payment obligations for Section 965 transition tax on untaxed foreign earnings – G7 Finance Ministers support OECD two-pillar proj...

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee reports out 4 tax protocols to full Senate – US Senate Finance Committee leaders urge Treasury to intensify efforts to convince France not to enact DST – IRS official says proposed GILTI regulations' "high taxed exclusion" prospective date meant to assess election's operation

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee to vote on protocols to US tax treaties with Switzerland, Luxembourg, Spain, and Japan on 25 June 2019 – US releases final GILTI regulations – IRS temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules – Ninth Circuit reverses US Tax Court in...

A review of the week's major US international tax-related news: US Senate may hold long-delayed tax treaty hearing – G20 finance ministers approve OECD's digital work plan – DC Circuit affirms Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co. SA – Final GILTI regulations due out before 22 June 2019.

A review of the week's major US international tax-related news: OMB completes review of final and proposed GILTI regulations; Treasury to release before 22 June – US participation exemption guidance clears OMB review – IRS issues proposed regulations on exception from tax for foreign pension fund interests in US real property – IRS LB&I withdraws RAB Share Directive for cost sharing arrangements.

A review of the week's major US international tax-related news: OECD releases digital taxation work program – OMB sets December 2019 target date for release of many high-profile international TCJA final regulations – IRS Commissioner says cryptocurrency guidance coming within 30 days – TIGTA issues report on IRS implementation of Section 965 deemed repatriation tax

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 956 regulations – Treasury official confirms final GILTI regulations by 23 June, BEAT regulations this summer – ECOFIN discusses digital taxation.

A review of the week's major US international tax-related news: US Treasury official warns over global DST proposals – New PTI regulations coming before year-end – IRS issues final FX regulations – IRS releases proposed CFC regulations under Sections 954 and 958 – Final GILTI regulations under OMB review – IRS Internal Legal Memo addresses Section 367(d)

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 1446(f) regulations on W/H for non-publicly traded partnerships – Proposed rules on FIRPTA exception for foreign pension funds expected soon – EU comments on IRC Section 250 proposed regulations, criticizes FDII

A review of the week's major US international tax-related news. In this edition: IRS officials say to expect release of proposed Section 1446(f) regulations, final FATCA regulations, and proposed regulations on repeal of Section 958(b)(4) – India ratifies US-India CbC exchange agreement

Description: A review of the week's major US international tax-related news. In this edition: IRS issues revised US Tax Treaty Table 1 – OECD publishes full version of OECD Model Tax Treaty – UN subcommittee releases report on tax challenges of digitalized economy.

A review of the week's major US international tax-related news. In this edition: US officials offer insights on global digital taxation – IRS LB&I launches 3 new international campaigns

A review of the week's major US international tax-related news. In this edition: US House and Senate tax leaders release digital taxation statement – IRS issues correction to final Section 965 transition tax regulations – Immediate action may be required for foreign-owned US disregarded entities – UN issues draft update to transfer pricing manual for developing countries – EU, UK reach agreement o...

A review of the week's major US international tax-related news. In this edition: US House Republican tax writers voice concern to President Trump about France's DST proposal – US officials comment on future final Section 250 FDII regulations – IRS's new APMA Functional Cost Diagnostic Model may be used in examinations in 'appropriate' cases – GAO issues report on FATCA – OECD Forum on Tax Administ...

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing debates benefits of 2017 TCJA, including international provisions – US, India sign CbC report exchange agreement – IRS releases 2018 APA report – Forum on Tax Administration releases report on tax aspects of sharing and the gig economy at plenary meeting  

A review of the week's major US international tax-related news. In this edition: OECD official offers timeline for global digital taxation project – IRS to release proposed previously taxed income (PTI) regulations in late summer or early fall – IRS issues final FATCA regulations – US-India bilateral agreement for exchange of CbC reports announced – OECD releases beneficial ownership toolkit

A review of the week's major US international tax-related news. In this edition: Final GILTI regulations out before summer, but "round 2" will address loss stock basis adjustment rules – EU comments on US Section 59A BEAT – US Treasury official confident of global consensus on digital allocation of taxing rights – OECD official says immediate goal is to finalize and present digital tax work plan t...

A review of the week's major US international tax-related news. In this edition: IRS releases Section 250 proposed regulations on determining deduction for FDII and GILTI – IRS announces hearings on proposed regulations on BEAT, hybrid mismatches – IRS APMA releases Functional Cost Diagnostic Model for APA requests – ITS updates FATCA FAQs – EY submits comments on OECD tax consultation on digitali...

A review of the week's major US international tax-related news. In this edition: OMB completed review of proposed FDII regulations – US government supports efforts to encourage countries to adopt corporate minimum tax – IRS LB&I memo requires transfer pricing issue teams to consult with APMA – IRS requesting comments on final regulations on imposition of Section 6662 accuracy-related penalty for S...