EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Efforts to update and align transfer pricing regulations and align them with TCJA now underway ─ NYSBA comments on Section 59A proposed Treasury regulations ─ General Court of the European Union annuls Commission's decision on Belgian excess profit rulings ─ OECD releases fifth batch of peer review reports on BEPS Act...

A review of the week's major US international tax-related news. In this edition: OECD opens public consultation on addressing tax challenges from digitalization of the economy – US Treasury official responds to OECD digitalization proposals – Finalization of US international tax regulations may pass June 2019 deadline

A review of the week's major US international tax-related news. In this edition: US Treasury official responds to OECD policy note on digital taxation – IRS will not relax anti-corporate inversion rules – Code Section 965 final regulations published in Federal Register; clarification on due date for filing transfer agreements

A review of the week's major US international tax-related news. In this edition: OECD issues major Policy Note relating to work on 'Addressing the Tax Challenges of the Digitalisation of the Economy' – OECD released Harmful Tax Practices – 2018 Progress Report on Preferential Regimes – US Senate tax leaders voice concern over European DST proposals – Congressional Democrats may use technical corre...

A review of the week's major US international tax-related news. In this edition: OECD BIAC releases 11 principles to guide tax reform for digital economy – OECD may address more than digital business activity, potentially impacting other IP-intensive business models

A review of the week's major US international tax-related news. In this edition: IRS releases final Section 965 transition tax regulations – US Senate Finance Committee's first priority is tax extenders legislation

New House Ways and Means Committee Chairman offers hints re: tax agenda – IRS issues final Section 163(j) Form and Instructions

A review of the week's major US international tax-related news. In this edition: US Congress fails to enact year-end tax legislation, Federal government enters into partial shutdown – Outgoing House Ways and Means Committee Chairman releases discussion draft of Tax Technical and Clerical Corrections Act – Status of OMB review of TCJA regulations during government shutdown unclear

A review of the week's major US international tax-related news. In this edition: US House approves tax bill; Senate action unlikely -- Congressional Joint Committee on Taxation releases general explanation of the Tax Cuts and Jobs Act (Blue Book) – IRS issues proposed regulations on Sections 245A(e) and 267A – IRS issues proposed regulations under Section 864(c)(8) on tax treatment of foreign part...

A review of the week's major US international tax-related news. In this edition: US House tax leader releases modified year-end tax package -- IRS releases proposed Section 59A Base Erosion and Anti-Abuse Tax (BEAT) regulations – IRS issues Section 965 transition tax FAQs -- OMB completes review of proposed TCJA Section 864c()(8) regulations; release imminent – IRS issues proposed FATCA, withholdi...

A review of the week's major US international tax-related news. In this edition: US Republican efforts to move tax legislation stall in House – US Treasury sends final Section 965 transition tax regulations, proposed regulations under Section 864(c)(8) to OMB for review – ECOFIN fails to reach agreement on proposed EU Digital Services Tax; US House tax leader weighs in

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on computing interest expense limitation under Code Section 163(j) – IRS releases complex foreign tax credit regulations – Congressional Republicans advance year-end tax legislation in lame-duck session

A review of the week's major US international tax-related news. In this edition: US, Singapore signed TIEA and new FATCA Model I IGA – OECD released update to 2017 Progress report on Preferential Tax Regimes – OECD Inclusive Framework on BEPS released substantial activities requirement for "no or only nominal tax" jurisdictions -- OECD now gathering input on implementation of BEPS Action 14 minimu...

A review of the week's major US international tax-related news. In this edition: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance –...

A review of the week's major US international tax-related news. In this edition: US mid-term election will affect tax in Congressional lame-duck and 2019 – Treasury sends TCJA's BEAT and FTC proposed regulations to OMB for review -- EU Ministers meet on proposed Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS recently issued Section 163(j) draft Form 8990, draft instructions for BEAT Form 8991 – IRS LB&I issues 3 more international tax compliance campaigns -- US House tax leader issues warning about propos...

A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existi...

A review of the week's major US international tax-related news. In this edition: Proposed FTC and Section 163(j) regulations release to OMB Office of Regulatory Affairs imminent -- Proposed PTI regulations unlikely to be released as complete package by year-end – 2018 IRS deadline for QI, Withholding Foreign Partnership and Withholding Foreign Trust applications is 16 November 2018 – OECD making p...

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA's FDII later this month -- US official says OECD making good progress on lon...

A review of the week's major US international tax-related news. In this edition: IRS Notice 2018-78 provides welcome amendments to Section 965 proposed regulations – IRS proposed regulations on GILTI to be published in Federal Register on 10 October 2018; 60-day comment period begins

A review of the week's major US international tax-related news. In this edition: US House moves forward with 'tax reform 2.0' – GILTI regulations to be finalized by June 2019 – IRS restructuring Advance Pricing and Mutual Agreement program.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations removing IRC Section 385 debt/equity documentation regulations – IRS releases draft Form 8991 on new Section 59A BEAT provision -- IRS Notice 2018-72 delays effective date of Section 871(m) dividend equivalent payments by two years – US House tax leader urges IRS to issue virtua...

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 951A GILTI regulations – IRS issues guidance on REIT Section 951A, foreign currency income inclusions – House tax writing committee approves Tax Reform 2.0

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-election session – House tax-writing committee to move Tax Reform 2.0 week of 10 September

A review of the week's major US international tax-related news. In this edition: OECD released fourth round of BEPS Action 14 peer reports on improving tax dispute resolution mechanisms.