EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: House approves budget deal -- IRS issues guidance on treatment under Sections 482 and 901 of transactions with foreign branches or disregarded entities.

On 5 December 2013, the UK Chancellor delivered his Autumn Statement, setting out a number of economic reforms with the aim of bringing down the deficit.

A review of the week's major US international tax-related news. In this edition: No House Ways & Means Committee tax reform draft legislation this year -- IRS issues final and proposed Section 871(m regulations addressing dividend equivalent payments on notional principal contracts, other equity-linked instruments.

A review of the week's major US international tax-related news. In this edition: House-Senate FY'14 budget conference committee deadline little over two weeks away -- IRS official says US, Indian competent authorities attempting to "normalize" relations -- Guidance under Section 901(m) on covered asset acquisitions,Section 905(c) on foreign tax redeterminations delayed.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee Chairman releases discussion draft on international tax reform -- US government reportedly has initialed 33 FATCA IGAs -- US, Vietnam to enter into tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: OECD holds public consultation on BEPS-related reporting and transfer pricing issues -- Update on US tax reform -- US, France announce signing of Model 1 FATCA IGA - Brazil publishes PM 627 with major corporate tax implications -- EY launches Global R&D Guide on ey.com.

The Australian government on 6 November 2013 said it would address the extensive backlog of previous tax and superannuation policy decisions announced, but not legislated by previous governments.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to release first tax reform draft within two weeks -- IRS rules there is a reduction in CFC's post-1986 foreign taxes corresponding to reduction in earnings from stock redemption.

On 30 October 2013, Law 16/2013 was published in the Spanish Official Gazette; it introduces relevant amendments to Spanish corporate income tax and extends the application of certain measures to FY 2014 and 2015.

A review of the week's major US international tax-related news. In this edition: House-Senate conference committee holds first meeting - Senate Finance Committee to release tax reform drafts in coming weeks - IRS issues Notice 2013-69 on FATCA - US, Hungary initial FATCA Model 1 IGA -- Mexican Congress approves tax reform

A review of the week's major US international tax-related news. In this edition: IRS rules certain growing activities qualify as production for subpart F foreign base company sales income rules -- ILM 201340016 considers triangular C reorg completed before release of Notice 2006-85 -- Update on Ireland's change to the Irish tax residency rules.

India's Central Board of Direct Taxes (CBDT) recently issued a notification for application of General Anti-avoidance Rules (GAAR).

Mexico's lower House of Congress revised and approved the proposed tax reform on 18 October 2013; it now moves on to the Senate for debate and vote.

A review of the week's major US international tax-related news. In this edition: Congress approves funding / debt bill; government reopens -- Ireland proposes change to tax residency rule to prevent "stateless" entities -- Italian Law Decree includes changes of interest to MNCs.

A review of the week's major US international tax-related news. In this edition: Movement on US fiscal impasse -- OECD country-by-country reporting may begin as early as 2014.

On 3 October 2013, the OECD published a memorandum seeking input on the development of an approach for country-by-country reporting of income, taxes paid, and economic activity.

An EY review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House; US opposes "virtual PE" concept and more.

A review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House -- US opposes "virtual PE" concept -- IRS concerned re: taxpayers unwinding so-called "sandwich structures" -- Two courts address STARS transactions.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans may tie movement on tax reform to legislation to raise the debt limit - Tax Court rules in BMC Software that accounts set up from Section 482 adjustment are related party indebtedness for Section 965 DRD.

In an opinion dated 6 September 2013, the European Council's lawyers concluded that the proposed Financial Transaction Tax counterparty rule is contrary to EU law.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess; no progress on fiscal issues -- IRS CCA looks at interest expense allocation / apportionment for FTC purposes -- Prop. regulations issued on limitations on importation of net built-in losses; international tax implications.

On 8 September 2013, Mexico's President Pena Nieto presented the long-awaited tax reform proposal to the Mexican Congress.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess to looming fiscal deadlines -- IRS issues final 901 regulations -- Final, temporary, and proposed regulations on application of straddle rules to debt instruments released.

A review of the week's major US international tax-related news. In this edition: US tax reform update -- IRS CCA concludes interest deductions on payments by US corporation to foreign parent disallowed under Section 267(a)(3) .

A review of the week's major US international tax-related news. In this edition: House and Senate committees continue work on tax reform during August recess -- IRS announces FATCA registration site available online.