Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: IRS releases final, proposed GILTI regulations on GILTI high exclusion, subpart F high tax exception – IRS official says proposed PTEP regulations coming before year-end – G20 discusses BEPS 2.0, OECD official comments on timeline.

A review of the week's major US international tax-related news. In this edition: IRS releases new draft partnership forms for 2021, Schedule K-2 and K-3 (Form 1065) – Treasury delivers two international tax-related regulatory projects to OMB’s OIRA for review – USTR announces action on France’s Digital Services Tax – OECD expects blueprint proposals for BEPS 2.0 Pillar 1 and 2 by October 2020 – OECD releases new corporate tax statistics, including aggregated CbCR data.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final FDII/GILTI regulations – OMB completes review of final regulations on GILTI high-tax exclusion, proposed rules under Section 954(b)(4) high-taxed subpart F income and Section 964 re: E&P of a foreign corporation – IRS seeing more multilateral APA requests – OECD releases model rules for reporting by platform operators regarding sellers in the sharing and gig economy.

A review of the week's major US international tax-related news. In this edition: US Supreme Court declines to hear Altera cost-sharing case – OECD’s Saint Amans says BEPS 2.0 Pillar 1 talks are ‘still alive’.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: Senate Republicans will not take up next coronavirus stimulus package until end of July – IRS seeks recommendations for 2020-2021 guidance projects – USTR releases USMCA regulations.

A review of the week's major US international tax-related news. In this edition: USTR launches investigations of new or proposed Digital Services Taxes in 10 jurisdictions – IRS lists US info exchange agreements re: certain deposit interest paid to residents of those jurisdictions – OECD announces release of Toolkit on the Taxation of Offshore Indirect Transfers.

A review of the week's major US international tax-related news. In this edition: US Treasury sends final FDII, GILTI deduction regulations to OMB for review – OECD official says governments refocusing on BEPS.

A review of the week's major US international tax-related news. In this edition: US government considers incentives to lure manufacturing back to the United States – Treasury announces USMCA to replace NAFTA references in US tax treaties – OECD holds virtual public consultation on 2020 review of CbC reporting.

A review of the week's major US international tax-related news. In this edition: US House set to pass HEROES Act stimulus legislation; Senate will not take up bill – IRS issues final Section 385 debt/equity regulations – IRS modifies MAP, APA filing procedures to reflect COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats poised to release fourth coronavirus relief package – IRS provides limited DCL and Form 8858 / 8865 relief for temporary activities resulting from coronavirus travel disruptions – OECD postpones July 2020 IF BEPS 2.0 meeting to October.

A review of the week's major US international tax-related news. In this edition: US Congress set to reconvene in May; timing of next COVID-19 stimulus bill uncertain – IRS updates FATCA FAQs, 1 July certification due date extended 15 December 2020.

A review of the week's major US international tax-related news. In this edition: President Trump signs $484 billion interim COVID-19 relief bill into law – IRS issues FAQs on interaction of CARES Act NOL carryback and Section 965 transition tax – IRS releases guidance for foreign businesses and nonresident aliens affected by COVID-19 travel disruptions – IRS issues FAQs on best practices and common mistakes in preparing transfer pricing documentation.

A review of the week's major US international tax-related news. In this edition: IRS grants relief for real estate, farming businesses to withdraw or make late Section 163(j)(7) elections, based on CARES Act – LB&I outlines compliance activities either postponed or allowed through 15 July 2020 – OECD BEPS 2.0 IF Steering Group agrees to continue project on current timelines.

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called ‘Midco’ listed transactions – IRS issues 2019 APA annual report.

A review of the week's major US international tax-related news. In this edition: Coronavirus Aid, Relief, and Economic Security Act (CARES Act) has international tax implications for multinationals – IRS issues interim guidance on offers in compromise re: Section 965 transition tax.

A review of the week's major US international tax-related news. In this edition: US Congress enacts $2t Coronavirus Aid, Relief, and Economic Security (CARES) Act stimulus package – IRS posts FAQs on extension of certain filing and payment deadlines to 15 July 2020 – IRS announces FATCA Report (Form 8966) filings due 31 March extended to 15 July 2020 – IRS unveils new People First Initiative to address COVID-19, temporarily suspends key compliance programs.

A review of the week's major US international tax-related news. In this edition: US government responds to COVID-19 pandemic, enacts Families First Coronavirus Response Act – US Senate Republicans release draft $1 trillion COVID-19 bill – US announces tax return filing, payment extensions – IRS issues final foreign tax credit regulations for covered asset acquisitions – OECD to go ‘full steam’ on BEPS 2.0 project – EY’s Global Tax Policy Center releases COVID-19 Stimulus Tracker.

A review of the week's major US international tax-related news. In this edition: IRS expects fewer corporate taxpayer participants in compliance assurance program due to strict eligibility requirements – TIGTA releases report on discrepancy findings that tax withholding required by FIRPTA is not being identified or addressed – Number of TCJA  tax regulations at the OMB's OIRA continues to grow – UK issues 2020 Budget confirming implementation of a 2% DST on revenues earned from 1 April 2020.

A review of the week's major US international tax-related news. In this edition: IRS will not issue regulations aligning transfer pricing rules to TCJA changes re: definition of intangible property before 2021 – House Republicans urge Treasury Secretary to withdraw portion of IRS Notice 2007-55 relating to REIT liquidating distributions – UK government will ‘consider’ US opposition to DST in lead up to trade talks.