EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: OECD releases outcome statement on BEPS 2.0 Pillars One and Two progress – US Congress considering action on a US-Taiwan tax agreement – US senators reissue crypto-assets legislative proposal, request more information – Joint Committee on Taxation issues digital asset report.

A review of the week's major US international tax-related news. In this edition: US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.

A review of the week's major US international tax-related news. In this edition: US Senate approves US-Chile income tax treaty – Congressional Joint Committee on Taxation releases revenue analysis of BEPS Pillar Two global minimum tax – BEPS Pillar One and Pillar Two developments expected in coming weeks.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee approves three separate tax packages – Proposed US-Chile income tax treaty may have final US Senate vote as early as 21 June – OMB's OIRA will no longer review Treasury tax regulations – OECD officials comment on BEPS Pillars One and Two.  

A review of the week's major US international tax-related news. In this edition: Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.  

A review of the week's major US international tax-related news. In this edition: US Congress passes debt ceiling legislation – US House Ways and Means Committee Republicans introduce legislation targeting OECD BEPS 2.0 Pillar Two Undertaxed Profits Rule – US Senate Foreign Relations Committee reports out proposed US-Chile income tax treaty – US House members introduce resolution calling for legisl...

A review of the week's major US international tax-related news. In this edition: US House Republicans to introduce anti-BEPS Pillar Two legislation – G-7 Finance Ministers welcome OECD progress report, reiterate commitment to BEPS Pillars One and Two – IRS to hire additional transfer pricing and competent authority staff, will expand CAP, APA and pre-filing programs.

A review of the week's major US international tax-related news. In this edition: OECD official offers insights on BEPS Pillar One and Pillar Two – US Senate Foreign Relations Committee may act on proposed US-Chile tax treaty – IRS official clarifies coming PTEP regulations in regard to partnerships.

A review of the week's major US international tax-related news. In this edition: President Biden, congressional leaders in debt ceiling talks, but no breakthroughs yet – US Senate Finance Committee holds hearing on cross-border pharma manufacturers and US international tax policy – US government officials discuss CAMT guidance, another notice coming – New US-Israel tax treaty in the works – US, Sw...

A review of the week's major US international tax-related news. In this edition: IRS releases proposed regulations on IP repatriation subject to Section 367(d) – Bipartisan US senators introduce bill to authorize negotiations with Taiwan to conclude tax agreement – US, Norway conducting tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: US House passes debt ceiling, spending bill – Treasury says no decision on interim CAMT guidance – IRS updates crypto notice – OECD to release BEPS Pillar Two qualified domestic minimum top-up tax safe harbor by summer.

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans introduce debt limit, spending bill – SEC Chairman defends agency's authority over cryptocurrency products.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess; will need to address debt ceiling and spending – IRS issues proposed rules on micro-captive transactions as listed transactions.

A review of the week's major US international tax-related news. In this edition: IRS will provide transition period for documentation requirements for FTC "single-country exception" – US Tax Court rules IRS lacks authority to assess penalties under Section 6038(b) – US, Germany sign competent authority arrangement on automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US' OECD contribution.

A review of the week's major US international tax-related news. In this edition: IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary testifies before Senate Finance Committee on FY '24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira's hyperinflationary status has US tax consequences.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

A review of the week's major US international tax-related news. In this edition: IRS will issue initial guidance on how far back to apply basis adjustments to arrive at "opening" books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US sharehol...

A review of the week's major US international tax-related news. In this edition: IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

A review of the week's major US international tax-related news. In this edition: President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, 'billionaire surtax' – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs,...

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.