EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee ranking member releases report on tax avoidance through financial products, deferred compensation – US to release updates to 2006 model tax treaty in draft form – OECD consensus building on BEPS Action 4 on interest deductions.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups set May deadline – Treasury officials offer US positions on OECD BEPS.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman says tax reform in 114th Congress must happen before August recess -- IRS concludes US shareholder must increase its E&P in year of Section 951(a)(1) inclusion -- IRS opines on application of tax rate disparity test for foreign sales branches – US anti-corporate inversion regulations...

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations under Section 909 on foreign tax credit splitting events --- China issues long-awaited indirect transfer rule replacing Circular 698

A review of the week's major US international tax-related news. In this edition: Obama Administration releases FY 2016 Budget, including international tax proposals – Ways and Means Committee holds hearing on proposed FY 2016 Budget – Treasury official offers insight on future anti-inversion regulations – OECD releases three more BEPS papers.

A review of the week's major US international tax-related news. In this ed(See attached file: 04 - Week ending 30 Jan.wav.zip)ition: President Obama to release FY 2016 Budget on 2 February - Finance Committee Chairman Orrin Hatch offers insights on tax working groups, international tax reform.

A review of the week's major US international tax-related news. In this edition: Obama Administration, Congressional Republican leaders stake out positions on future tax reform debate – US, India agree on framework to resolve competent authority cases; clears way for US-India APAs.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans talk tax reform – President Obama to deliver State of Union Address on 20 January -- The Stop Tax Haven Abuse Act reintroduced in Congress -- IRS launches FATCA International Data Exchange Service.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes -- Sen. Hatch assumes chairmanship of Finance Committee -- FATCA developments -- IRS CCA 201501013: Foreign fund's activities through US fund manager constitute US trade or business.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes 6 January – IRS releases PLR 20145200002 on FTC recapture.

A review of the week's major US international tax-related news. In this edition: President Obama announces Administration will release specific proposals on tax reform – Tax extenders legislation signed into law – IRS releases final regulations (T.D. 9707) with respect to filing of Form 5472.

A review of the week's major US international tax-related news. In this edition: Congress enacts tax extenders legislation -- Obama Administration may release detailed business tax reform plan in 6-9 months - Incoming Senate Finance Committee Chairman discusses guidelines for tax reform -- IRS officials offer thoughts on inversion guidance -- OECD releases 6 BEPS discussion drafts.

A review of the week's major US international tax-related news. In this edition: Congress poised to pass tax extenders legislation -- Incoming Senate Finance Committee Chairman releases tax reform report -- OECD BEPS update -- IRS updates FATCA Q&As on withholding certification forms -- SEC says more disclosure about foreign taxes may be necessary -- UK releases more details on diverted profits ta...

A review of the week's major US international tax-related news. In this edition: House approves one-year tax extenders legislation -- IRS announces jurisdictions treated as having FATCA IGA, but not yet signed, will retain status beyond 31 December 2014 -- UK Autumn Statement includes new 'diverted profits tax' proposal.

A review of the week's major US international tax-related news. In this edition: Congressional negotiators reach tentative tax extenders deal; President Obama threatens veto -- OECD releases public discussion draft on follow-up work on treaty abuse under BEPS Action 6.

A review of the week's major US international tax-related news. In this edition: Tax extender negotiations continue in Congress -- Rep. Paul Ryan to chair Ways & Means Committee, Sen. Orrin Hatch to lead Finance Committee in 114th Congress -- IRS issues final and temporary regs on failure to file timely GRAs, other reporting; IRS Directive on GRAs revoked -- IRS issues CCA 201446020 on back-to-bac...

A review of the week's major US international tax-related news. In this edition: Congress begins lame-duck session; tax extenders under negotiation -- House may consider REIT/PFIC change -- IRS finalizes regulations on all-cash D reorganizations -- Treasury continues work on anti-inversion guidance -- Treasury considering limited FATCA relief for IGAs in substance -- BEPS communique expected follo...

A review of the week's major US international tax-related news. In this edition: Obama Administration continuing to move forward on potential guidance to curb corporate inversion transactions -- 51 jurisdictions pledge to abide by automatic tax information exchange.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee considering need for anti-inversion stop gap measure -- US Claims Court in Albemarle rules contested foreign tax liability accrues in year to which it relates, not year resolved and paid.

A review of the week's major US international tax-related news. In this edition: Treasury notifies 17 Model I IGA jurisdictions of MFN option -- IRS CCA 201441015 disallows domestic parent's deemed paid foreign taxes paid -- Ireland's FY'15 Budget includes improvement to IP regime, phasing out of "double Irish".

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-58 on economic substance -- FATCA developments reviewed -- OECD updates calendar for draft BEPS discussion papers, public consultations -- EY conference participants polled on BEPS.

A review of the week's major US international tax-related news. In this edition: US government officials offer perspectives on OECD BEPS action items.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-52 to counter corporate inversions -- Treasury considering expanding covered asset acquisition rules under Section 901(m); PFIC guidance coming -- EY Alerts / Webcasts on OECD BEPS deliverables available -- Congress adjourns for mid-term elections; lame duck session may bring tax technical corre...

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS deliverables in 7 focus areas -- Obama Administration confirms it will address inversions shortly.

A review of the week's major US international tax-related news. In this edition: Congress returns from August recess; focuses on anti-inversion options -- OECD to release first seven deliverables under BEPS Action Plan on 16 September 2014 -- IRS issued CCA 201436047; accrued but unpaid interest is an obligation under Section 956 -- IRS Notice 2014-51 announces PFIC marked to market exception