Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news: US Treasury official warns over global DST proposals – New PTI regulations coming before year-end – IRS issues final FX regulations – IRS releases proposed CFC regulations under Sections 954 and 958 – Final GILTI regulations under OMB review – IRS Internal Legal Memo addresses Section 367(d)

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 1446(f) regulations on W/H for non-publicly traded partnerships – Proposed rules on FIRPTA exception for foreign pension funds expected soon – EU comments on IRC Section 250 proposed regulations, criticizes FDII

A review of the week's major US international tax-related news. In this edition: IRS officials say to expect release of proposed Section 1446(f) regulations, final FATCA regulations, and proposed regulations on repeal of Section 958(b)(4) – India ratifies US-India CbC exchange agreement

Description: A review of the week's major US international tax-related news. In this edition: IRS issues revised US Tax Treaty Table 1 – OECD publishes full version of OECD Model Tax Treaty – UN subcommittee releases report on tax challenges of digitalized economy.

A review of the week's major US international tax-related news. In this edition: US officials offer insights on global digital taxation – IRS LB&I launches 3 new international campaigns

A review of the week's major US international tax-related news. In this edition: US House and Senate tax leaders release digital taxation statement – IRS issues correction to final Section 965 transition tax regulations – Immediate action may be required for foreign-owned US disregarded entities – UN issues draft update to transfer pricing manual for developing countries – EU, UK reach agreement on 6-month Brexit delay

A review of the week's major US international tax-related news. In this edition: US House Republican tax writers voice concern to President Trump about France’s DST proposal – US officials comment on future final Section 250 FDII regulations – IRS’s new APMA Functional Cost Diagnostic Model may be used in examinations in ‘appropriate’ cases – GAO issues report on FATCA – OECD Forum on Tax Administration announces ICAP 2.0

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing debates benefits of 2017 TCJA, including international provisions – US, India sign CbC report exchange agreement – IRS releases 2018 APA report – Forum on Tax Administration releases report on tax aspects of sharing and the gig economy at plenary meeting  

A review of the week's major US international tax-related news. In this edition: OECD official offers timeline for global digital taxation project – IRS to release proposed previously taxed income (PTI) regulations in late summer or early fall – IRS issues final FATCA regulations – US-India bilateral agreement for exchange of CbC reports announced – OECD releases beneficial ownership toolkit

A review of the week's major US international tax-related news. In this edition: Final GILTI regulations out before summer, but “round 2” will address loss stock basis adjustment rules – EU comments on US Section 59A BEAT – US Treasury official confident of global consensus on digital allocation of taxing rights – OECD official says immediate goal is to finalize and present digital tax work plan to G-20 Finance Ministers and leaders, OECD technical working parties to follow

A review of the week's major US international tax-related news. In this edition: IRS releases Section 250 proposed regulations on determining deduction for FDII and GILTI – IRS announces hearings on proposed regulations on BEAT, hybrid mismatches – IRS APMA releases Functional Cost Diagnostic Model for APA requests – ITS updates FATCA FAQs – EY submits comments on OECD tax consultation on digitalization of the economy

A review of the week's major US international tax-related news. In this edition: OMB completed review of proposed FDII regulations – US government supports efforts to encourage countries to adopt corporate minimum tax – IRS LB&I memo requires transfer pricing issue teams to consult with APMA – IRS requesting comments on final regulations on imposition of Section 6662 accuracy-related penalty for Section 482 adjustments

A review of the week's major US international tax-related news. In this edition: Efforts to update and align transfer pricing regulations and align them with TCJA now underway ─ NYSBA comments on Section 59A proposed Treasury regulations ─ General Court of the European Union annuls Commission's decision on Belgian excess profit rulings ─ OECD releases fifth batch of peer review reports on BEPS Action 14

A review of the week's major US international tax-related news. In this edition: OECD opens public consultation on addressing tax challenges from digitalization of the economy – US Treasury official responds to OECD digitalization proposals – Finalization of US international tax regulations may pass June 2019 deadline

A review of the week's major US international tax-related news. In this edition: US Treasury official responds to OECD policy note on digital taxation – IRS will not relax anti-corporate inversion rules – Code Section 965 final regulations published in Federal Register; clarification on due date for filing transfer agreements

A review of the week's major US international tax-related news. In this edition: OECD issues major Policy Note relating to work on ‘Addressing the Tax Challenges of the Digitalisation of the Economy’ – OECD released Harmful Tax Practices – 2018 Progress Report on Preferential Regimes – US Senate tax leaders voice concern over European DST proposals – Congressional Democrats may use technical corrections as leverage for tax incentives

A review of the week's major US international tax-related news. In this edition: OECD BIAC releases 11 principles to guide tax reform for digital economy – OECD may address more than digital business activity, potentially impacting other IP-intensive business models

A review of the week's major US international tax-related news. In this edition: IRS releases final Section 965 transition tax regulations – US Senate Finance Committee’s first priority is tax extenders legislation

New House Ways and Means Committee Chairman offers hints re: tax agenda – IRS issues final Section 163(j) Form and Instructions

A review of the week's major US international tax-related news. In this edition: US Congress fails to enact year-end tax legislation, Federal government enters into partial shutdown – Outgoing House Ways and Means Committee Chairman releases discussion draft of Tax Technical and Clerical Corrections Act – Status of OMB review of TCJA regulations during government shutdown unclear