Ey Cross-border Taxation Alerts

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.

A review of the week's major US international tax-related news. In this edition: OMB completes review of final regulations under Sections 245(e) and 267A – G20 endorse BEPS 2.0 “Outline of the Architecture of a Unified Approach on Pillar One” as basis for negotiations.

A review of the week's major US international tax-related news. In this edition: US official says major TCJA international tax guidance on track for release by October 2020; provides unofficial timeline – Altera files writ of certiorari with US Supreme Court in cost sharing case – OECD expected to reach agreement on core BEPS 2.0 Pillar 1 and 2 principles by close of 2020 – OECD issues Consultation Document on “sharing” and “gig” economy.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary confirms US-France DST de-escalation agreement – Treasury Secretary defends TCJA international guidance at congressional hearing – Senate Finance Committee Democrats introduce GILTI amendment – OECD issues final TP report on financial transactions – OECD releases CbCR consultation document – OECD reports BEPS 2.0 Pillar 1 and 2 would raise additional $100b global CIT annually.

A review of the week's major US international tax-related news. In this edition: IRS has no plans to issue additional Section 965 transition tax guidance – IRS will accept PLR requests for determining BEAT base erosion payment – OMB sends final Section 163(j) business interest deduction limitation regulations back to Treasury – Singapore announces US-Singapore TIEA in force 5 March 2020.

A review of the week's major US international tax-related news. In this edition: US supports OECD Pillar 1 proposals as ‘safe harbor’ – IRS rules target's capitalized transaction costs do not create separate and distinct intangible asset – UK leaves EU on 31 January 2020, begins transition period – OECD Inclusive Framework on BEPS meets on Pillar 1 and 2 proposals.

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations for contributions of appreciated property by US persons to partnerships with related foreign partners – IRS’s recently announced Section 965 repatriation relief is case-by-case – US officials comment on pending Section 245A DRD and Section 163(j) interest limitation guidance – US, France trade war over French DST on hold through 2020; France suspends collection of DST.

A review of the week's major US international tax-related news. In this edition: IRS may revise broad definition of interest in pending final Section 163(j) regulations – IRS may amend FMV requirement in proposed regulations for phaseout of LIBOR, variant interest rates – IRS will consider cryptocurrency PLRs – France will not eliminate DST notwithstanding US retaliatory tariffs.

A review of the week's major US international tax-related news. In this edition: USTR holds hearing on tariffs in response to France’s DST – TCJA final regulations on Section 163(j) and hybrid dividends and payments pending OMB review.

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on W/H and reporting tax re US source income paid to foreign persons – IRS proposed regulations modify rules for sourcing income from sales of inventory within/outside US – FinCen further extends FBAR filing deadline – US hopeful pending US tax treaties with Chile, Hungary, and Poland will be approved in 2020 – OECD release additional CbC reporting guidance.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation with CFC look-through provision – IRS issues final Section 871(m) regulations on dividend equivalent payments, extends transition relief – US Treasury sends final Section 163(j) regulations and final Section 267A hybrid mismatch regulations to OMB for review – OECD and US Treasury officials comment on BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: OECD holds public consultation on GloBE Pillar 2 proposals – OECD to release economic modeling of Pillar 1 and Pillar 2 proposals in early 2020.

A review of the week's major US international tax-related news. In this edition: IRS releases final BEAT regulations – IRS issues final and proposed FTC regulations – IRS Notice 2019-65 defers applicability date of final Section 987 regulations and related rules by one additional year – US has ‘serious concerns’ over OECD BEPS 2.0 Pillar 1 – USTR proposes punitive duties on French goods over France’s new DST.

A review of the week's major US international tax-related news. In this edition: Participants at OECD public consultation on BEPS Pillar One identify existing global transfer pricing system as needing change – US government holds release of foreign tax credit, BEAT regulations – Spanish Supreme Court rules US RIC entitled to Spanish dividend WHT refund.  

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on ownership attribution rules for CFC purposes – OMB fall 2019 agenda includes new IRS final reg project on rules for domestic shareholders’ accounting method changes for foreign corporations – OECD holds public consultation on BEPS Pillar One project.

A review of the week's major US international tax-related news. In this edition: Release of IRS foreign tax credit, BEAT regulations imminent – US Treasury officials offer international tax guidance timeline – Ninth Circuit Court of Appeals denies request for en banc rehearing in Altera v. Commissioner – EY submits comment letter on OECD Pillar 1 consultation document. .

A review of the week's major US international tax-related news. In this edition: IRS announces new Section 965 transition tax campaign – IRS warns against using transfer pricing to avoid BEAT – OECD releases Pillar 2 Consultative Document – OECD issues more CbCR guidance – OECD announces new Analytical Database on MNEs and affiliates – OECD releases additional guidance on spontaneous information exchange by no, low-tax jurisdictions.

A review of the week's major US international tax-related news. IRS issues final Section 385 regulations removing minimum documentation requirements; announces it will modify “distribution regulations” – OMB completes review of final and proposed FTC regulations – Congressional JCT releases Blue Book explanation for tax legislation enacted in 115th Congress – Draft IRS partnership form and instructions reflect new Section 864(c)(8) – UK receives Brexit extension until 31 January 2020; general election 12 December.

A review of the week's major US international tax-related news. Update on US international guidance at OMB OIRA – IRS to continue scrutiny of virtual currency transactions – IRS concludes Section 952(c) election to include excludible insurance income in subpart F income of CFCs’ US shareholder is obsolete – G20 expresses support for OECD’s two-pillar approach.

A review of the week's major US international tax-related news. US Congress considers spending bill as vehicle for tax extenders, TCJA technical corrections – UK, EU reach agreement on new Brexit deal – OECD hopes to finalize digital tax proposal details in January, political agreement by June 2020.