Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Biden Administration, Congressional Republicans show some willingness to compromise on infrastructure package – Treasury Green Book detailing President Biden’s tax proposals to be released end of May – House Financial Services Committee reports out CbC financial reporting bill, including taxes – IRS modifies accounting method change guidance related to certain foreign corporations.

A review of the week's major US international tax-related news. In this edition: US Congress, Biden Administration focused on infrastructure plans, proposed tax increases – IRS releases updated early drafts of new Schedules K-2 and K-3, for Forms 1065, 1120-S, and 8865, for 2021 tax year – OECD considering framework for elimination of unilateral DSTs post-BEPS 2.0 agreement – OECD cryptoasset project delayed to 2022.

A review of the week's major US international tax-related news. In this edition: US President Joe Biden addresses joint session of Congress, makes case for multi-trillion dollar American Jobs Plan and American Families Plan – Treasury details plan to direct $80 billion to IRS over next 10 years – PTEP proposed regulations now expected to be released in multiple installments, beginning late summer, early fall 2021 – UN releases third edition of UN Transfer Pricing Manual.

A review of the week's major US international tax-related news. In this edition: President Biden to address joint session of Congress; will pitch infrastructure and American Families Plan proposals – Senate Finance Committee Chairman reintroduces Clean Energy for America Act – UN tax committee approves new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden begins outreach on $2.2 trillion American Jobs Plan – IRS issues proposed regs on foreign investment in Opportunity Zone funds – IRS issues FAQs on International Compliance Assurance Program (ICAP) – EY submits comments on EU Public Consultation on digital levy.

A review of the week's major US international tax-related news. In this edition: US Treasury releases report on Biden Administration’s Made in America Tax Plan – US Senate Finance Committee Chairman releases framework for international taxation – US presents OECD BEPS 2.0 Pillar One proposal to steering group of Inclusive Framework on BEPS – UN Tax Subcommittee releases final draft of new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden unveils $2 trillion infrastructure plan to be paid for with higher CIT rate, international tax changes – US, Japan reach agreement on tax treaty arbitration process – IRS APMA Program releases annual APA update – US Trade Representative proposes 25% punitive tariffs on Austria, India, Italy, Spain, Turkey, and the UK in response to Digital Services Taxes – OECD initiates consultation on commentary to Article 9 (Associated Enterprises) of OECD Model Tax Treaty. .

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee holds hearing on international taxation – US, 18 other jurisdictions to participate in OECD ICAP – IRS releases practice unit on Section 965 transition tax. .

A review of the week's major US international tax-related news. In this edition: Biden Administration begins to float tax proposals – Senate Finance Committee holds hearings on various aspects of US Tax Code – House, Senate Democrats release international tax bills – IRS official offers international tax guidance update – IRS updates FATCA FAQs.

A review of the week's major US international tax-related news. In this edition: US enacts $1.9 trillion COVID-19 stimulus legislation, including repeal of worldwide interest expense allocation election – IRS Office of Fraud Enforcement initiative to focus on virtual currency – IRS Advance Pricing and Mutual Agreement Program seeing questionable treatment of COVID-related costs – OECD official sees possibility for two simplification measures in BEPS 2.0 Pillar 2 agreement – Platform for Collaboration on Tax issues final version of Toolkit for Tax Treaty Negotiations.

A review of the week's major US international tax-related news. In this edition: US Senate considers $1.9 trillion COVID relief package – US Treasury Secretary takes Pillar 1 safe harbor off table in BEPS 2.0 talks – Murillo named Treasury Deputy Assistant Secretary for International Tax Affairs.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to vote on $1.9 trillion COVID-19 stimulus/relief package on 26 February, action next moves to Senate – US Treasury nominee says goal in BEPS 2.0 talks is to protect US tax revenue and ensure a level playing field.

A review of the week's major US international tax-related news. In this edition: US Congressional tax leader says no consensus on international tax changes – “Platform for Collaboration on Tax” releases toolkit to help developing countries with effective transfer pricing documentation requirements – OECD Forum on Tax Administration releases new handbook for International Compliance Assurance Program (ICAP) – OECD issues 2021 Global Forum Capacity Building Report.

A review of the week's major US international tax-related news. In this edition: US House tax-writing committee approves package representing half of $1.9 trillion COVID relief plan, including international tax provision – Treasury may open project to revive transfer pricing aggregation regulations.

A review of the week's major US international tax-related news. In this edition: US Congress may address international tax regime in 2021, Senate aide says – US, Argentina sign agreement to share CbC reports – OECD holds public consultation on BEPS Action 14 dispute resolution –  Final draft of ‘Platform for Collaboration on Tax’ to be released in Q1 2021.

A review of the week's major US international tax-related news. In this edition: New US Treasury Secretary commits to OECD BEPS 2.0 discussions – OECD releases guidance on COVID-19 related tax treaty issues.

A review of the week's major US international tax-related news. In this edition: President Biden inaugurated as US president; Treasury-designate Janet Yellen confirms tax increases to be delayed – US to re-engage in OECD BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US President-elect Joe Biden announces $1.9 trillion “American Rescue Plan” – Incoming US Senate Finance Committee Chairman Ron Wyden details economic and tax priorities – IRS guidance on Section 864(f) worldwide interest expense allocation a top priority in 2021 – USTR announces investigation findings re Digital Service Taxes in Austria, Spain, and United Kingdom.

A review of the week's major US international tax-related news. In this edition: Democrats control over White House and US Congress has implications for legislation and tax in 2021 – Treasury and IRS release final Section 163(j) business interest expense limitation regulations – US suspends tariff action over Section 301 investigation of France’s Digital Services Tax – OECD Pillar One and Two Blueprint public consultation will be held 14-15 January 2021; Inclusive Framework meeting 27-28 January will be public.

A review of the week's major US international tax-related news. In this edition: Congress passes $2.3 trillion omnibus spending and coronavirus stimulus legislation with tax extenders; President Trump calls on Congress to pass new bill – OECD issues COVID-19-related transfer pricing guidance.