Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: OECD releases Pillar One Consultation Document on digitalization of the economy – IRS Notice 2019-58 addresses final, temporary, and proposed Section 385 debt/equity regulations – IRS issues guidance on tax treatment of cryptocurrency transactions – Foreign tax credit and Section 59A BEAT regulations pending OMB OIRA review.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations on TCJA repeal of Section 958(b)(4) for determining CFC status – IRS releases Rev. Proc. 2019-40 on repeal of Section 958(b)(4); details safe harbors.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry into force of tax protocols with Luxembourg and Switzerland – Bipartisan US Senate lawmakers in early discussions on tax extenders legislation; CFC look-through expires at year-end – European General Court rules Netherlands did not grant illegal State aid to Starbucks – OECD holds first Tax Certainty Day; 2018 MAP statistics released  

A review of the week's major US international tax-related news. In this edition: US Treasury sends final and proposed Section 59A BEAT regulations to OMB for review – IRS reconsidering Form 1120-F nonfilers compliance campaign following TIGTA review – OECD official says Pillar 1 and Pillar 2 proposals will incorporate tax certainty as a core component.

A review of the week's major US international tax-related news. In this edition: US Congress: Update on technical corrections, tax extenders, new tax treaties – International tax-related TCJA fall guidance – Protocol to US-Luxembourg tax treaty enters into force – US, France in talks over Digital Services Tax; US may take action against other nations’ unilateral digital taxes.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry-into-force dates for protocols to US-Japan and US-Span tax treaties.

A review of the week's major US international tax-related news. In this edition: French President comments on new Digital Services Tax – IRS lists jurisdictions with reporting requirements for interest and OID paid to certain NRAs

A review of the week's major US international tax-related news. In this edition: US Ninth Circuit affirms Tax Court’s Amazon transfer pricing decision – IRS will permit domestic partnerships, S corporations to apply rules from proposed GILTI regulations for tax years ending before 22 June 2019 – USTR holds hearing on France’s Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on cloud-based, digital transactions – Revised version of IRS Publication 5188 on reporting FATCA data released – OECD issues BEPS Action 14 Stage 2 peer review reports on dispute resolution; includes US.

A review of the week's major US international tax-related news. In this edition: IRS formally withdraws “Altera” CSA memo in light of Ninth Circuit decision – President Trump signs instruments of ratification to tax protocols amending treaties with Luxembourg, Switzerland, Japan, and Spain

A review of the week's major US international tax-related news. In this edition: US threatens retaliation against France’s new DST – IRS begins sending virtual currency letters to taxpayers

A review of the week's major US international tax-related news. In this edition: Altera Corp. files petition for rehearing challenge of 2003 cost sharing regs – IRS publishes final regs relating to the allocation of creditable foreign tax expenditures by a partnership – UK’s Boris Johnson to succeed Theresa May as Prime Minister; UK publishes draft legislation and consultation paper on EU MDR – OECD updates peer review of preferential tax regimes

A review of the week's major US international tax-related news. In this edition: US Senate approves four protocols updating the existing bilateral tax treaties with Luxembourg, Switzerland, Japan and Spain – IRS releases additional information to assist with filing and payment obligations for Section 965 transition tax on untaxed foreign earnings – G7 Finance Ministers support OECD two-pillar project to develop new rules for taxing multinational businesses – 2019 UN tax treaty negotiation manual updated to reflect changes in 2017 UN Model Treaty – APMA’s functional cost diagnostic model intended to help officials with complex cases

A review of the week's major US international tax-related news. In this edition: US government initiates review of France’s new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee reports out 4 tax protocols to full Senate – US Senate Finance Committee leaders urge Treasury to intensify efforts to convince France not to enact DST – IRS official says proposed GILTI regulations’ “high taxed exclusion” prospective date meant to assess election’s operation

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee to vote on protocols to US tax treaties with Switzerland, Luxembourg, Spain, and Japan on 25 June 2019 – US releases final GILTI regulations – IRS temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules – Ninth Circuit reverses US Tax Court in Altera v. Commissioner – US, Cyprus negotiating CA agreement to exchange CbC reports

A review of the week's major US international tax-related news: US Senate may hold long-delayed tax treaty hearing – G20 finance ministers approve OECD’s digital work plan – DC Circuit affirms Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co. SA – Final GILTI regulations due out before 22 June 2019.

A review of the week's major US international tax-related news: OMB completes review of final and proposed GILTI regulations; Treasury to release before 22 June – US participation exemption guidance clears OMB review – IRS issues proposed regulations on exception from tax for foreign pension fund interests in US real property – IRS LB&I withdraws RAB Share Directive for cost sharing arrangements.

A review of the week's major US international tax-related news: OECD releases digital taxation work program – OMB sets December 2019 target date for release of many high-profile international TCJA final regulations – IRS Commissioner says cryptocurrency guidance coming within 30 days – TIGTA issues report on IRS implementation of Section 965 deemed repatriation tax

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 956 regulations – Treasury official confirms final GILTI regulations by 23 June, BEAT regulations this summer – ECOFIN discusses digital taxation.