EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Renewed push for US tax reform after Labor Day – Trump Administration expects Congress to take lead on reform legislation.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans to release details on tax reform in "short order" – "Big 6" negotiators looking for revenue for tax reform.

A review of the week's major US international tax-related news. In this edition: White House tax negotiators and congressional leaders plan to release document outlining framework for tax reform -- Congressional tax staffers to focus on anti-base erosion rules now that proposed border adjustment tax will not be adopted.

A review of the week's major US international tax-related news. In this edition: US corporate tax rate may settle in low to mid-20% range – IRS extends transition period for applying parts of Section 871(m) rules – IRS now accepting Form 8975, Country-by-Country Report and Schedules A.

A review of the week's major US international tax-related news. In this edition: Trump Administration outlines new strategy for enacting US tax reform – Kautter confirmed as new Treasury Assistant Secretary (Tax Policy) -- Tax Court holds US parent's CFCs held US property under Section 956 as result of intercompany transactions -- Tax Court rules IRS abused its discretion in cancelling two APAs –...

A review of the week's major US international tax-related news. In this edition: House border adjustability proposal no longer under consideration for US tax reform – Few repeal recommendations expected in final report on 8-Obama-era tax regulations deemed significant -- US signs 5 more Competent Authority Arrangements for automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House Budget Committee approves FY 2018 budget resolution with reconciliation instructions for US tax reform – White House official says "Big 6" and their staffs making headway on US tax reform – US Senate Finance Committee advances nomination of David Kautter for Treasury Assistant Secretary for Tax Policy -- US T...

A review of the week's major US international tax-related news. In this edition: Trump Administration wants draft tax reform plan "locked in place" before Congress' August recess – Senate Finance Committee and House Ways and Means Tax Policy Subcommittee to hold tax reform hearings next week -- OECD released draft contents of next update to OECD Model Tax Convention.

A review of the week's major US international tax-related news. In this edition: Robert Stack addresses prospect of territorial tax system at University of Oxford tax conference – Chairman Brady and Speaker of the House Ryan to possibly continue advocating for border adjustment tax – President Trump's nominee for Treasury assistant secretary for tax policy David Kautter moves forward – US IRS anno...

A review of the week's major US international tax-related news. In this editio enate Finance Committee turns to US tax reform -- IRS finalizes Form 8975, Schedule A, Instructions for CbC Reporting – OECD to release new TP Guidelines, final report on branch mismatch structures, and MLI database.

A review of the week's major US international tax-related news. In this edition: US House Speaker calls for comprehensive, permanent tax reform in 2017 – IRS has signed 12 CA agreements for CbCR exchange – OECD releases discussion drafts on PE profit attributions, revised guidance on profit splits – OECD announces TP toolkit for developing nations lacking data.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman proposes 5-year border adjustability phase-in period – IRS considering ways to simplify FTIN process – IRS reconsidering transfer pricing case selection – US, Canada sign CbC competent authority agreement.

A review of the week's major US international tax-related news. In this edition: Trump Administration preparing detailed tax reform plan for Congress – US signed five competent authority agreements for exchanging CbC reports – US considering agreeing to and publicizing transfer pricing safe harbor rules – 68 jurisdictions signed Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary pressed on how to pay for tax reform – Congressional supporters of border adjustability proposal not giving up – OMB Director says Administration does not necessarily support deficit neutral tax reform.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means tax reform hearing focuses on border adjustability -- Senate Majority Leader expresses optimism for US tax reform -- Trump Administration releases $4.094 trillion FY 2018 Budget blueprint.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee held first hearing on tax reform in new Congress – W&M hearing on border adjustability proposal scheduled for 23 May – Trump Administration to release FY'18 Budget on 23 May -- US Treasury has begun review of final, temporary and proposed tax regulations issued after 1 January 2016 –...

A review of the week's major US international tax-related news. In this edition: Trump Administration officials discuss tax reform with Republican Senate Finance members – President Trump comments on border adjustability, suggests 10% repatriation rate – House Ways and Means Committee to hold tax reform hearing on 18 May – Trump Administration nominates Dave Kautter as Treasury Assistant Secretary...

A review of the week's major US international tax-related news. In this edition: President Trump says Administration's tax reform plan is open to negotiation – House Republican goal now to develop single tax reform proposal palatable to both Administration and Congress – US Treasury making progress in negotiating competent authority agreements to exchange CbC reports -- OECD released update on exc...

A review of the week's major US international tax-related news. In this edition: Trump Administration releases tax reform plan -- President Trump signs Executive Order to review significant tax regulations issued since 1 January 2016 – US Tax Court rules modification of variable prepaid forward contracts does not trigger gain realization – IRS files notice of appeal in Medtronic transfer pricing c...

A review of the week's major US international tax-related news. In this edition: Trump Administration confirms tax reform in 2017 – White House to release tax reform plan "very soon" – Treasury may resume issuing tax regulations – President to sign Executive Order to review significant tax regulations issued in 2016.

A review of the week's major US international tax-related news. In this edition: Trump Administration to return to ACA repeal, then tax reform.

A review of the week's major US international tax-related news. In this edition: US tax reform, another health care deal dominated discussions before Congressional recess – IRS extended deadline for submitting QI, foreign withholding partnership, and foreign withholding trust agreement renewal requests -- IRS APMA issued 18th annual Advance Pricing Agreement report –- OECD released updated guidanc...

A review of the week's major US international tax-related news. In this edition: President Trump and Congressional Republicans pivot to tax reform following ACA repeal failure – UK triggers Brexit; sets stage for complex negotiations with EU.

A review of the week's major US international tax-related news. In this edition: TUS House Ways and Means Committee Chairman expects Blueprint's border adjustability proposal will be included in US tax reform; but with phase-in and modifications – IRS to resume issuing "sub-regulatory" guidance – US Tax Court rules for Amazon.com, Inc., in transfer pricing cost sharing case – Country-by-Country Re...

A review of the week's major US international tax-related news. In this edition: Tax reform takes backseat as Congress focuses on health care reform – Senate Majority Leader less optimistic for completing tax reform by August recess – Treasury official expects government to resume issuing tax guidance sooner, rather than later.