EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Congressional tax leaders express concern over Treasury plans for CbC reporting regulations – IRS CCA addresses "relation back" doctrine in Section 905(c) -- IRS FFA concludes portions of intercompany referral fee income generated by foreign subs improperly characterized as Subpart F income – IRS releases more inte...

A review of the week's major US international tax-related news. In this edition: Congress returns on 8 September to series of legislative and budgetary deadlines – Ways and Means international tax reform plan to be drafted in September; markup in October.

A review of the week's major US international tax-related news. In this edition: IRS finalizes two revenue procedures related to requesting assistance from the US competent authority under US tax treaties and requesting an APA – US Court of Appeals for the Federal Circuit affirms decision in Albemarle Corp. v. United States case.

A review of the week's major US international tax-related news. In this edition: Treasury Department releases 2015-2016 Priority Guidance Plan – IRS and Treasury release Notice 2015-54 – Senate Finance Committee's tax extenders bill, the Tax Relief Extension Act of 2015, gets filed in the Senate – Tax Court makes decision in Altera v. Commissioner case.

A review of the week's major US international tax-related news. In this edition: Senior House Ways and Means Committee members released an "innovation box" discussion draft -- Senate subcommittee held a hearing on "Impact of the US Tax Code on the Market for Corporate Control and Jobs.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves 2-year tax extenders bill -- Senate to consider 6-year highway authorization bill; contrasts with House approach – US Treasury official outlines upcoming international tax guidance.

A review of the week's major US international tax-related news. In this edition: House passes interim highway funding bill to allow for long-term funding plan tied to international tax reform – Senate Finance Committee releases Chairman's Mark of "tax extenders" bill; committee markup 21 July – Finance Committee chairman voices BEPS concerns on Senate floor.

A review of the week's major US international tax-related news. In this edition: Senate Finance tax reform working groups release final reports, including international tax – US, Vietnam sign first-ever tax treaty.

A review of the week's major US international tax-related news. In this edition: Congress to return from recess to tackle Highway Trust Fund; repatriation, international tax reform possible revenue sources -- Deadline for Senate Finance Committee's tax reform working groups pushed to early July -- World Customs Organization publishes Guide to Customs Valuation and Transfer Pricing – Possible 'Grex...

A review of the week's major US international tax-related news. In this edition: House W&M subcommittee hearing looks to repatriation to fund Highway Trust Fund – Senate Finance Committee working group on international tax reform hands in report – Legislation introduced to close PFIC "loophole" reportedly used by US hedge fund reinsurers.

A review of the week's major US international tax-related news. In this edition: W&M Chairman says US international tax reform and making tax extenders permanent will dominate 2015 tax agenda in Congress -- IRS may require CbC reports to be filed with corporate returns in September 2017 – Public comments on proposed changes to US Model Tax Treaty due 15 September 2015.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group will present findings on 26 June -- House Ways and Means Committee international tax reform component will propose hybrid territorial tax system with broad innovation box – Congressional tax leaders relay concern over BEPS to Treasury – OECD releases CbC reporting impleme...

A review of the week's major US international tax-related news. In this edition: IRS issues final anti-corporate inversion regulations – OECD issues discussion draft on BEPS Action 8 on hard-to-value intangibles -- Seven countries join OECD agreement to exchange financial information automatically.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups receive deadline extension -- DC Appeals Court rules 1% federal excise tax on reinsurance premiums inapplicable to retrocession agreements between foreign entities -- IRS reiterates US corporation in outbound F reorganization prior to effective date of Notice 2012-39...

A review of the week's major US international tax-related news. In this edition: US Treasury releases new Model Tax Treaty provisions – US business tax reform in 2015 may be limited – OECD releases revised discussion draft on Action 7, artificial avoidance of PE status.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee international tax reform legislative text expected this summer -- US District Court in Lehman Brothers disallows FTCs in back-to-back stock loan transaction – ABA Tax Section meeting highlights coming US international tax guidance – OECD Update: public consultation held on BEPS Action 12...

A review of the week's major US international tax-related news. In this edition: Senate passes House-Senate conference report with reconciliation instructions – IRS issues Rev. Rulings 2015-09 and 2015-10 clarifying certain cross-border internal restructurings.

A review of the week's major US international tax-related news. In this edition: IRS this week releases Notice 2015 – House of Representatives on 30 April passes the House-Senate conference agreement on the FY 2016 budget resolution addressing tax reform and tax extenders – the OECD releases discussion draft on cost contribution arrangements in connection with Action 8 (transfer pricing aspects of...

A review of the week's major US international tax-related news. In this edition: IRS issues proposed PFIC insurance regulations that address Senate Finance Committee member's concerns – IRS releases proposed regulations under Section 5000C – IRS CCA 201516064 clarifies short term loan exception under IRS Notice 88-108.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group reviewing options - IRS confirms interaction of PFIC look-through rules in PLR 201515006 - OECD releases discussion draft on Action 11(Improving the analysis of BEPS).

A review of the week's major US international tax-related news. In this edition: Congress returns from 2-week recess; Senate Finance tax reform working groups resume work -- OECD releases Discussion Draft on CFC rules under Action 3.

A review of the week's major US international tax-related news. In this edition: OECD releases Discussion Draft on Action 12 (Disclosure of aggressive tax planning arrangements) – US officials comment on BEPS Actions 8, 9, 10.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee leaders offer international tax reform insights -- OECD holds public consultation on BEPS Actions 8-10 on transfer pricing -- US will focus on international tax administration and mutual agreement procedures post-BEPS.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee focuses on international tax reform – Fifth Circuit Court of Appeals reverses Tax Court in BMC Software; A/R created following transfer pricing adjustment does not constitute indebtedness for Section 965 purposes – US Treasury official: 25 countries may be interested in mandatory binding arbit...

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee Chairman has concerns over Obama Administration's international tax proposals – Finance Committee requesting tax ideas on tax reform; international hearing slated for 17 March -- IRS to begin scheduling pre-filing conferences for bilateral APAs with India – US opposes risk, recharacterization,...