Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Inclusive Framework on BEPS announces agreement on Two Pillar solution – US Congressional Democrats’ dispute over size of Build Back Better budget reconciliation bill continues – OECD publishes two MLI opinions.

A review of the week's major US international tax-related news. In this edition: US Congress grapples over infrastructure, budget reconciliation legislation – G7 Finance Ministers make progress on BEPS 2.0 issues in lead up to October 2021 meetings -- IRS lists jurisdictions with which it has information exchange for reporting certain deposit interest paid.

A review of the week's major US international tax-related news. In this edition: White House, House and Senate Democrats discussing path forward on budget reconciliation bill – IRS APMA director warns taxpayers against unilateral relief.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee clears major tax bill to partially fund Build Back Better Act; includes major changes to US international tax rules – IRS seeing $1 billion MAP cases, LB&I official says.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee begins budget reconciliation markup – Treasury pushes for 21 percent minimum corporate tax on foreign earnings – Senate Finance Committee Chairman releases draft partnership tax legislation – Treasury official offers update on coming final foreign tax credit regulations – IRS releases 2021–2022 Priority Guidance Plan – IRS allows taxpayer to reverse "gap period" transaction through late CTB election.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee to begin markup the week of 6 September re: Budget Resolution – IRS articulates five-factor test in determining income inclusion of reimbursement payments – US, France sign joint statement on spontaneous exchange of CbC reports for FYs beginning 2020 and 2021.

A review of the week's major US international tax-related news. In this edition: US House passes FY 2022 budget resolution on path to trillion-dollar reconciliation bill; infrastructure vote no later than 27 September – Senate Finance Committee Chairman, committee members provide details on international tax framework proposals – IRS extends date for W/H on certain transfers, distributions related to publicly traded partnership interests to 1 January 2023.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to convene to consider FY 2021 Budget Resolution – US, Germany agree to share CbC reporting information.

A review of the week's major US international tax-related news. In this edition: US Senate passes $1.2 trillion infrastructure bill, $3.5 trillion budget resolution with reconciliation instructions – Senate Finance Committee Chairman releases financial derivatives overhaul proposal – IRS official says new financial entities campaign will be broad.

A review of the week's major US international tax-related news. In this edition: US Senate moves toward passage of $1.2 trillion bipartisan infrastructure bill – OECD confirms US government’s intention to abolish Foreign Derived Intangible Income regime.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan Senate negotiators reach agreement on $1.2 trillion infrastructure package; Senate Democrats have votes to move on budget resolution – US, UK competent authorities sign agreements re: NAFTA and derivative benefits in treaty LOB – Treasury official offers international tax regulatory update – OECD releases sixth batch of peer reports on BEPS Action 14 minimum standard on dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Senate Majority leader misses initial infrastructure legislation and budget resolution deadlines – IRS addresses cost sharing agreements and inclusion of stock-based compensation costs –  OECD plans to complete work on BEPS 2.0 multilateral convention and model domestic legislation by close of 2021, early 2022.

A review of the week's major US international tax-related news. In this edition: Senate Budget Committee Democrats agree on $3.5 trillion budget resolution, paving way for “human infrastructure” paid for with tax increases – Bipartisan $1 trillion infrastructure negotiators given 21 July deadline – Biden Administration wants global minimum tax in budget reconciliation package; Pillar Two elements on slower track.

A review of the week's major US international tax-related news. In this edition: OECD announces conceptual agreement in BEPS 2.0 project – IRS issues early draft instructions for amended Schedules K-2 and K-3 for 2021 Forms 1065, 1120-S, and 8865.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan senators agree to infrastructure deal – OECD publishes Model Reporting Rules for Digital Platforms: International Exchange Framework.

A review of the week's major US international tax-related news. In this edition: More US Senators publicly support $1.2 trillion bipartisan infrastructure compromise – House passes corporate disclosure package requiring country-by-country tax reporting for multinationals.

A review of the week's major US international tax-related news. In this edition: Bipartisan US Senate group proposes $1.2 trillion infrastructure package – G7 Finance Ministers express strong support for ongoing work on OECD BEPS 2.0 project – Biden Administration’s proposed 15% minimum tax on book earnings could include public disclosure of book-tax differences – IRS announces deferral of applicability date of BEAT qualified derivative payment reporting – Treasury discusses information reporting proposals regarding virtual currencies.

A review of the week's major US international tax-related news. In this edition: US Treasury ‘Green Book’ details Biden Administration’s international tax proposals – President Biden, Senate Republicans continue infrastructure talks – USTR announces and suspends tariffs over digital services taxes – G-7 officials begin meeting; expected to pledge support for BEPS 2.0 talks.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing discusses US international tax proposals – Biden Administration, Senate Republicans trading infrastructure proposals.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing on infrastructure highlights differences regarding scope and pay-fors – US Treasury proposes 15% global minimum corporate tax rate – IRS official discusses application of US treaties’ derivative benefits test post-Brexit – OECD Multilateral Instrument Conference of the Parties issues interpretative opinion.