EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Treasury officials offer updates on TCJA international guidance -- IRS LB&I issued guidelines for delinquent Forms 1120-F, waiver requests – EU surveying European multinationals re: US tax reform.

A review of the week's major US international tax-related news. In this edition: US government issues more repatriation transition guidance in Rev. Proc. 2018-17 – Treasury officials offer insights on future international TCJA guidance – US to defend TCJA's FDII provision as WTO-compliant – IRS taking leadership role in OECD's International Compliance Assurance Program -- OECD released more BEPS A...

Updated US Treasury/IRS 2017 - 2018 Priority Guidance Plan issued with TCJA projects – Treasury to delay effective date of final Section 987 branch currency regulations to 2020 – US to begin tax treaty negotiations with Armenia

A review of the week's major US international tax-related news. In this edition: US Treasury addresses tax guidance for TCJA – Joint Committee on Taxation reviewing issues for TCJA technical corrections, but no date – 'Off-year' Blue Book on TCJA possible.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-13 – Treasury close to determining fate of Section 385 debt/equity regulations -- Treasury Secretary attempts to ease European concerns regarding US tax reform legislation.

A review of the week's major US international tax-related news. In this edition: US technical tax corrections bill on hold for now – IRS LB&I issues series of internal transfer pricing directives – IRS says taxpayers can elect mark-to-market method of accounting in recent Section 988 proposed regulations.

A review of the week's major US international tax-related news. In this edition: US Treasury grants further extension for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2018-07 on new transition tax – IRS suspends W/H obligations under new Section 1446(f) for certain publicly traded partnership interests – FASB to issue additional guidance on ASC 740, Income Taxes, re: provisions in Tax Cuts and Jobs Act -- US Tax Court rules 6-year limitations period in Section 650...

A review of the week's major US international tax-related news. In this edition: US tax reform has tax accounting implications; SEC offers financial statement reporting relief – EU voices concern over US tax reform's international provisions.

A review of the week's major US international tax-related news. In this edition: US Congress passes landmark tax reform legislation, President Trump signs bill into law – House Republican tax leader says more US tax legislation coming – IRS issues proposed FX regulations – US, Spain sign CAA to exchange CbC Reports – IRS to appeal Grecian Magnesite Mining to DC Circuit Court of Appeals.

A review of the week's major US international tax-related news. In this edition: US tax reform bill finalized; Congress to vote week of 18 December -- US, France sign joint statement on exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House, Senate vote to go to conference committee to reconcile final tax reform bill – Transition period floated for tax reform international provisions – Repeal of ACA mandate may be included in final tax reform bill – Treasury official expects considerable "sub-regulatory guidance" after enactment of tax reform.

A review of the week's major US international tax-related news. In this edition: US Senate poised to pass US tax reform bill -- IRS may not complete bilateral CAAs by year-end for exchange of CbC reports -- IRS issues proposed regulations on international issues related to new partnership audit regime -- IRS rules GRA term fixed as of date of initial transfer -- US to appeal IRS violated APA regar...

A review of the week's major US international tax-related news. In this edition: US Senate to consider Finance Committee tax reform bill after Thanksgiving holiday – Congressional Republicans, Trump Administration officials aim to enact tax reform by year-end.

A review of the week's major US international tax-related news. In this edition:US House of Representatives approves comprehensive tax reform bill – US Senate Finance Committee reports out tax bill; consideration on Senate floor expected week of 27 November.

A review of the week's major US international tax-related news. In this edition:Congress moving forward on competing tax reform bills; action expected -- IRS announces 3 new international tax compliance campaigns -- OECD published updated Transfer Pricing Country Profiles.

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee releases comprehensive tax reform bill -- Treasury considering clarifications to 'F' reorganization regulations -- US official suggests non-delta-one transaction rules in Section 871(m) dividend equivalent regulations may not take effect.

A review of the week's major US international tax-related news. In this edition:House approves Senate-passed FY 2018 budget resolution; Ways and Means Committee tax reform bill set for release 1 November, legislative markup to begin 6 November – Treasury official says Section 385 debt/equity regulations 'overly burdensome' and will be substantially amended – David Kautter, current Treasury Assista...

A review of the week's major US international tax-related news. In this edition: US Senate approves FY 2017 budget resolution with tax reform reconciliation instructions – Treasury Secretary, House Speaker expect tax reform in 2017 – Administration official says tax reform details negotiable, except 20% CIT rate and middle-class relief

A review of the week's major US international tax-related news. In this edition:US House Republicans remain committed to enacting tax reform in 2017 – Foreign minimum tax may be necessary to adopt US territorial tax system – Bipartisan group of House tax writers call for partial withdrawal of FIRPTA Notice 2007-55

A review of the week's major US international tax-related news. In this edition:US House and Senate Republicans move forward on reconciliation instructions for passage of US tax reform -- Senate Finance Committee holds hearing on international tax reform – US Treasury issues report on 8 tax regulations identified as burdensome, including debt/equity and FX regulations – IRS Notice 2017-57 announce...

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans release tax reform framework -- IRS issues draft update of APA template – OECD releases first peer review reports on minimum standards on Action 14, improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Senate Budget Committee agrees on FY '18 Budget Resolution; implications for tax reform – "Big 6" tax reform consensus document released next week – US Treasury to publicly release report on "significant tax regulations" in September – IRS official upbeat on countries' implementation of OECD dispute resolution reco...

A review of the week's major US international tax-related news. In this edition: US Tax Reform "consensus document" set for release week of 25 September – President Trump pushes for 15% CIT rate – Treasury/IRS Guidance Plan to be released in fall – Deadline for Treasury to report recommendations on "significant tax regulations" 18 September.

A review of the week's major US international tax-related news. In this edition: Congress approves bill to provide hurricane relief funding – President Trump calls for Democrats to join him in support of an "American Model" of tax reform – OECD releases further guidance on CbC Reporting – Lafayette G. "Chip" Harter III appointed deputy assistant secretary for international tax affairs for the US T...