EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Congress returns next week from August recess -- OECD to release multiple BEPS reports and recommendations during week of 15 September.

A review of the week's major US international tax-related news. In this edition: IRS releases 2014-2015 Priority Guidance Plan -- IRS finalizes rules applying straddle rules to certain debt instruments -- IRS addresses when late-received documentation can support portfolio interest exemption.

A review of the week's major US international tax-related news. In this edition: Congress returns after Labor Day for short session -- Proposed anti-inversion legislation expected in September.

A review of the week's major US international tax-related news. In this edition: Senator Charles Schumer releases outline of his legislative proposal to address inversions by targeting earnings stripping practices -- IRS releases its first private letter ruling on Section 7874 anti-inversion rules – IRS issues Revenue Procedus pa014-47 that provides guidance for entering into a withholding foreign...

A review of the week's major US international tax-related news. In this edition: Congressman Levin releasesdiscussion draft of legislation that would tighten the earnings stripping rules of Section 163(j) -- Obama Administration reviews possible actions that could limit companies' ability to engage in inversions – OECD releasesreport on the impact of BEPS in low income countries -- OECD seeking in...

A review of the week's major US international tax-related news. In this edition: Congress mulls anti-inversion options -- IRS will apply forthcoming FTC regulations to certain entity classification elections following covered asset acquisitions -- OECD BEPS report on digital economy will not propose new tax regime.

A review of the week's major US international tax-related news. In this edition: Corporate inversions dominate Senate Finance Committee hearing -- IRS Notice 2014-44 announces forthcoming regulations under Section 901(m) -- IRS names acting director of transfer pricing operations -- OECD publishes Standard for Automatic Exchange of Financial Account Information in Tax Matters.

OECD publishes Standard for Automatic Exchange of Financial Information in Tax Matters

A review of the week's major US international tax-related news. In this edition: Growing anti-inversion sentiment in Congress -- IRS issues final regulations under Section 861 -- CCA: IRS can notify w/holding agent of foreign taxpayer's incorrect claim of w/holding tax exemption -- OECD Council approves update to OECD Model Tax Treaty -- IRS official offers international guidance update.

There were several Mexican tax developments that took place on 4 July 2014, affecting maquiladoras among other changes.

A review of the week's major US international tax-related news. In this edition: Speculation on departures of top international IRS officials -- House Ways and Means Committee and Senate Finance Committee pass separate highway funding bills.

A review of the week's major US international tax-related news. In this edition: IRS releases FATCA guidance in run up to 1 July 2014 effective date -- Shakeup at the IRS Large Business and International Division -- US Congress to take up Highway Trust Fund after 4 July recess.

A review of the week's major US international tax-related news. In this edition: US and China reached agreement in substance on FATCA Model 1 IGA -- Corporate repatriation appears off radar to sustain Highway Trust Fund -- Final regs to change rules for failure to comply with GRAS, other filings "imminent".

A review of the week's major US international tax-related news. In this edition: Congress mulls repatriation to pay for Highway Trust Fund -- US Senate Foreign Relations Committee holds hearing on Spanish protocol, new Polish tax treaty -- Treasury official: Solutions for all BEPS issues may not be possible.

A review of the week's major US international tax-related news. In this edition: Congress mulls tax repatriation to pay for Highway Trust Fund -- FATCA audits to begin early 2016 -- European Commission begins state aid investigations for Ireland, Netherlands, and Luxembourg regarding corporate tax paid by three MNCs.

A review of the week's major US international tax-related news. In this edition: House, Senate leaders concerned about BEPS -- OECD Tax Conference confirms 2014 BEPS action items timeline -- Pending US tax treaties and protocols (again) blocked in Senate -- Finance Committee announces summer tax reform hearings -- Senate Majority Leader says tax extenders "dead" until after mid-term election -- IR...

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves more permanent tax extender bills; Chairman Camp moves to "incremental tax reform" approach -- IRS to permit financial institutions to use existing forms through 2014 to sort entity accounts for FATCA purposes.

A review of the week's major US international tax-related news. In this edition: US anti-inversion legislation introduced in House and Senate -- Update on tax extenders -- OECD holds two public consultations: on hybrid mismatch arrangements and TP documentation and country-by-country reporting -- Proposed 2013 US-Poland tax treaty transmitted to Senate.

A review of the week's major US international tax-related news. In this edition: Tax extenders and corporate inversions dominate Congressional tax debate – US government officials offer insights at ABA Tax Section meeting.

On 6 May 2014, a declaration on automatic exchange of information in tax matters was adopted at the meeting of the OECD Council at the Ministerial Level; it was endorsed by 48 countries and the EU.

In Notice 2014-33, the IRS announced it will treat calendar years 2014 and 2015 as a transition period for purposes of enforcing and administering implementation of FATCA by all withholding agents (including foreign financial institutions).

A review of the week's major US international tax-related news. In this edition: Proposed US tax agreements delayed in Senate (again) -- US-Spain protocol transmitted to Senate -- Senate to move on tax extenders package next week -- US corporate inversions attract Congressional attention -- IRS Proposed Section 381 regulations have international implications.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves six separate bills to make permanent certain expired business tax provisions -- IRS official says BEPS causing some treaty partners to take aggressive positions -- IRS's top FACTA priority is release of final forms and instructions.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to mark-up tax extenders soon -- Senate tax extenders bill to go to floor week of 28 April -- IRS Notice 2014-32 addresses foreign triangular reorganizations -- IRS extends expanded PFIC active banking exception for qualifying government bonds.

On 16 April 2014, the Australian Taxation Office (ATO) released two new draft transfer pricing Taxation Rulings and new two draft Practice Statements, which represent the ATO's first documented view on how the new transfer pricing laws will apply and what taxpayers need to do.