Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Treasury sends final Section 163(j) interest expense limitation regulations to OMB for review – Treasury notes progress on new tax treaty with Croatia; resumption of US Senate approvals of bilateral tax treaties expected – IRS will continue to prioritize transfer pricing enforcement in examinations, even if adjustment negated by TCJA provisions – Treasury’s FINCEN further extends FBAR filing deadline – OECD BEPS 2.0 Pillar 1 and Pillar 2 comment period ends; BIAC calls for limited BEPS agreement by June 2021 – OECD publishes jurisdiction-specific information on implementation of hard-to-value intangibles approach.

A review of the week's major US international tax-related news. In this edition: IRS APMA Program seeing more COVID-19-related queries regarding APAs – OECD to release COVID-focused TP guidance by end of 2020, beginning 2021 – OECD’s FTA announces piloted International Compliance Assurance Program to become full-fledged program in 2021.

A review of the week's major US international tax-related news. In this edition: OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 Blueprints on 14-15 January 2021 – IRS releases final and proposed PFIC regulations – IRS issues final regulations under Sections 245A and 951A that coordinate two sets of anti-abuse rules – IRS LB&I releases internal guidance re: examinations with Section 965 transition tax issues.

A review of the week's major US international tax-related news. In this edition: IRS to release revenue procedure on interaction of GILTI and CFC change of accounting method – US, Mexico renew CA agreement on unilateral APAs for maquiladoras – New IRS guidance on stock-based compensation re cost sharing arrangements coming – PLRs possible on tax treatment of virtual currency transactions – OECD issues consultation document on BEPS Action 14, Making Dispute Resolution More Effective.

A review of the week's major US international tax-related news. In this edition: Joe Biden projected as winner of US Presidential election; tax policy changes examined – IRS updates listing of CAAs for CbC reports.

A review of the week's major US international tax-related news. In this edition: US elections remain undecided – IRS will not release PTEP proposed regulations by year-end – OECD releases report on taxing virtual currencies.

A review of the week's major US international tax-related news. In this edition: IRS announces plans to limit “telescoping” in APA and MAP cases – IRS turning its attention to enforcement, including international partnerships and cost sharing – IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership.

A review of the week's major US international tax-related news. In this edition: IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR end will not result in deemed taxable exchange – IRS will consider amending existing APAs due to effects of COVID-19 pandemic – US government announces US-Hong Kong shipping agreement will terminate effective 1 January 2021.

A review of the week's major US international tax-related news. In this edition: OECD and Inclusive Framework release series of documents on Pillar 1 and 2 of BEPS 2.0 Project, with new mid-2021 completion – G20 Finance Ministers approve progress and timeline – EU agrees to abide by new OECD Inclusive Framework timeline – UN releases new proposed model treaty article and commentary on taxing digital economy.

A review of the week's major US international tax-related news. In this edition: US government releases final partnership withholding regulations under Section 1446 – IRS announces new compliance campaign targeting NRA’s unreported US rental income – Inclusive Framework holds meeting on final BEPS 2.0 Pillar 1 and 2 blueprints; release expected 12 October 2020.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final and newly proposed foreign tax credit regulations – US Treasury issues final sourcing regulations on sales of personal property (including inventory) – OECD releases outcomes of third phase of peer reviews on BEPS Action 13.

A review of the week's major US international tax-related news. In this edition: Treasury releases final and proposed regulations on determining CFC status for certain provisions following TCJA repeal of Section 958(b)(4) – Final Treasury regulations under Section 864(c)(8) address US tax consequences of foreign partner's transfer of a partnership interest – OECD will publish final BEPS 2.0 Pillar 1 and 2 blueprints on 12 October 2020.

A review of the week's major US international tax-related news. In this edition: US Congress remains focused on bipartisan negotiations over next coronavirus aid package, extending government funding past 30 September FY-end – Democratic presidential nominee Joe Biden’s campaign releases additional tax proposals – IRS Notice 2020-73 announces one year deferral of certain Section 987 final regulations, related rules – G20/OECD Inclusive Framework on BEPS to meet 8-9 October, agreement on Pillar 1 unlikely.

A review of the week's major US international tax-related news. In this edition: Section 163(j) final regulations to be published in Federal Register on 14 September 2020; would be applicable to tax years starting 13 November 2020 – French Finance Minister accuses US of hindering progress in BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: IRS issues final Base Erosion and Anti-abuse Tax (BEAT) regulations – IRS Notice 2020-69 announces plans to issue regulations on application of Sections 951 and 951A to certain S corporations with accumulated E&P – IRS requests comments on collection of information for competent authority requests – OMB OIRA receives final and proposed FTC regulations for review.

A review of the week's major US international tax-related news. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – US, Swiss competent authorities agree to arbitration procedures under tax treaty.

A review of the week's major US international tax-related news. In this edition: US Senate Republicans reportedly planned limited coronavirus aid package not yet released – IRS Large Business and International division gearing up for major increase in refund claims through Form 1120-X as result of coronavirus aid legislation.

A review of the week's major US international tax-related news. In this edition: US Congress begins August recess, no agreement on coronavirus aid legislation – OMB completes review of final rules on DRD limitation for dividends from certain foreign corporations, proposed rules coordinating certain regulations under Section 245A and Section 951A – Draft Schedules K-2 and K-3 for 2021 tax year IRS partnership Form 1065 guided by need to standardize format, officials say.

A review of the week's major US international tax-related news. In this edition: Congress continues talks over another coronavirus bill, no deal reached – Final BEAT regulations now under OIRA review – IRS may refine Tested Unit Rule under GILTI High-Tax Exclusion rules – UN Tax Committee members issue proposal regarding taxation of digital services income.

A review of the week's major US international tax-related news. In this edition: IRS issues highly-anticipated final and proposed Section 163(j) interest limitation regulations and related guidance – IRS will add compliance resources to review stock-based compensation in cost-sharing arrangements.