EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to begin drafting international tax reform legislation immediately – Newly revised US Model Income Tax Treaty released – Treasury official comments on EU State Aid investigations.

A review of the week's major US international tax-related news. In this edition: President Obama releases FY 2017 Budget – Treasury Secretary Lew testifies before two Congressional tax-writing committees on President's FY 2017 budget proposal – Special counsel to IRS associate chief counsel (international) John Merrick talks about anti-inversion guidance at PLI conference in NYC – Former EY nation...

A review of the week's major US international tax-related news. In this edition: House tax reform leadership forming – Treasury official delivers State Aid concerns to EU – IRS issues guidance on partnership allocations of creditable foreign tax expenditures under Section 704 – Treasury poised to release updated US Model Tax Treaty – IRS to accept bilateral APA applications with India beginning 16...

A review of the week's major US international tax-related news. In this edition: European Commission releases major anti-tax avoidance package -- 31 countries sign Multilateral Competent Authority Agreement for automatic exchange of CbC reports -- Senate Finance Committee draft corporate integration plan could be developed within a few months – US anti-inversion regulations to be released soon .

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee reviewing options for corporate tax integration – House Ways and Means to hold hearings on inversions, repatriation in 2016; names Chief Tax Counsel – IRS Notice 2016-10 announces forthcoming regulations on RICs' foreign tax refunds.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says international tax reform bill mark-up coming in 2016 – President Obama delivers final State of the Union Address – US Treasury considering a foreign goodwill exception in final Section 367 regulations.

A review of the week's major US international tax-related news. In this edition: Congress returns to session; international tax reform under discussion – US MNC will owe $86 million in withholding tax, plus interest, in stipulated Tax Court decision – Sixth Circuit reverses Tax Court, concludes FX option can qualify as foreign currency contract.

A review of the week's major US international tax-related news. In this edition: IRS will no longer apply 1% excise tax to retrocession agreements between two foreign reinsurance companies – Congressional tax leader introduces bill to delay US country-by-country reporting until 2017.

A review of the week's major US international tax-related news. In this edition: US releases proposed country-by-country (CbC) reporting regulations – House tax leader says international tax reform next on the agenda – More upcoming international tax guidance coming.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation – Treasury officials offer insights on tax treaty negotiations, anti-corporate inversion guidance and EU state aid investigations.

A review of the week's major US international tax-related news. In this edition: Temporary tax extenders legislation on hold pending Congressional negotiations over more comprehensive package – IRS official previews upcoming international tax guidance.

A review of the week's major US international tax-related news. In this edition: Congressional hearings highlight concern over BEPS, EU State aid investigations and inversions –Negotiations continue on bipartisan tax extenders package.

A review of the week's major US international tax-related news. In this edition: Congressional leaders, Obama Administration negotiating tax extenders deal -- House and Senate to hold hearings on OECD BEPS project -- Delayed applicability date for aspect of Section 871(m) dividend equivalent payment regulations – IRS upgrades FATCA Online Registration System.

A review of the week's major US international tax-related news. In this edition: US Treasury releases additional anti-corporate inversion guidance – Tax extenders legislation delayed until December – Speaker calls for House passage of tax reform before Republicans choose a presidential candidate.

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee approves eight proposed tax agreements -- Possibility to link US international tax reform and tax extenders legislation before year-end.

A review of the week's major US international tax-related news. In this edition: New Ways and Means Committee Chairman to tackle tax extenders – House approves 6-year highway bill; formal conference committee with Senate expected – White House releases text of Trans-Pacific Partnership – Treasury may narrow proposed rule eliminating exception for outbound transfer of goodwill.

A review of the week's major US international tax-related news. In this edition: W&M Committee Chairman Paul Ryan elected House Speaker – Senate Foreign Relations Committee holds hearing on eight tax treaties and protocols - US Treasury reviewing new UK Diverted Profits Tax to determine its creditability for US FTC purposes.

A review of the week's major US international tax-related news. In this edition: W&M Committee Chairman Paul Ryan will run for House Speaker -- IRS to begin targeting inbound middle market companies for TP exams in regard to distribution functions -- IRS will begin accepting bilateral APAs with India beginning January 2016 – EU Commission issues anticipated decisions in State aid cases relating to...

A review of the week's major US international tax-related news. In this edition: G20 Finance ministers endorse final package of BEPS deliverables – Recent legislation creates new FBAR filing date, extension option

A review of the week's major US international tax-related news. In this edition: OECD releases final BEPS reports – Nearly half of surveyed tax directors plan significant changes to tax profile due to BEPs -- Tax agenda uncertain with House leadership in flux – Ways and Means Committee Chairman urged to seek House Speakership.

A review of the week's major US international tax-related news. In this edition: Speculation whether US House leadership change may impact limited tax reform package in this Congress – OECD set to release final reports on all 15 BEPS Actions – IRS announces additional Exchange Agreements with 16 countries.

A review of the week's major US international tax-related news. In this edition:IRS Notice 2015-66 announces extension of certain FATCA transitional rules – US announces FATCA Competent Authority Agreements with Australia, UK -- US district court rules denial of discretionary tax treaty benefits subject to judicial review – UK HMRC brief explains treatment of US LLCs following UK Supreme Court dec...

A review of the week's major US international tax-related news. In this edition: IRS final and temporary regulations under Section 871(m) issued on dividend equivalents – IRS issued final Section 368 "F" reorganization regulations -- House Ways and Means Committee approves bills to make permanent Subpart F active financing exception and CFC-to-CFC look-through rule.

Final OECD BEPS deliverables to be released 5 October – Congress returns from August recess to possibility of US international tax reform – IRS issues final Section 988(d) regulations -- Second Circuit affirms Tax Court in two foreign tax credit generator cases.

IRS releases final and temporary Subpart F regulations -- Congress returns 8 September to various pending deadlines – Final OECD BEPS deliverables slated for release this fall.