Ey Cross-border Taxation Alerts

IRS releases Section 965 proposed regulations on TCJA repatriation transition tax -- Ninth Circuit reverses Tax Court in Altera cost sharing case – DC Circuit overturns Tax Court in Good Fortune Shipping, rules Section 883 ‘”bearer share” regulations invalid -- IRS FATCA certification portal is now live

A review of the week's major US international tax-related news. In this edition: US House tax leader releases Tax Reform 2.0 framework – OMB completes review of Proposed Section 965 transition regulations – OECD Secretary-General Report to G20 Finance Ministers and Central Bank Governors on BEPS, tax transparency released

A review of the week's major US international tax-related news. In this edition: US House Republicans to release outline of proposals for “phrase 2” tax reform bill week of 23 July 2018 – OMB review of proposed Section 965 repatriation transition regulations pending -- Treasury official offers insights into coming TCJA international tax guidance – IRS official say countries reviewing how to use CbC reporting data

A review of the week's major US international tax-related news. In this edition: US international-focused tax technical corrections bill expected following November elections – Tax Reform 2.0 may fine-tune new international provisions – IRS issues final anti-corporate inversion regulations – IRS LB&I announces two new compliance campaigns on repatriation of foreign earnings -- IRS LB&I issues transfer pricing, automatic exchange of information memos – US Treasury Inspector General for Tax Administration releases negative FATCA report – OECD issues discussion draft on financial transactions under BEPS Actions 8-10

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee Chairman Kevin Brady discusses tax reform 2.0 – IRS to issue new proposed rules this year for controlled foreign corporations’ previously taxed income – proposed regulations withdrawing the Section 385 debt-equity documentation rules officially “pending review” – OECD Multilateral Convention to enter into force on 1 July 2018 – OECD announces publication of stakeholder comments it received in response to request for public comments on revisions to OECD Transfer Pricing Guidelines – OECD launches comparable tax revenue database

A review of the week's major US international tax-related news. In this edition:US Supreme Court rules in South Dakota v. Wayfair; major impact on all companies with sales to US, including foreign-based companies – US House Budget Committee approves FY 2019 budget resolution -- OECD releases two reports, on Hard-to-Value Intangibles and application of Transactional Profit Split Method

A review of the week's major US international tax-related news. In this edition: US congressional tax leader wants ‘phase 2’ reform bill released before August recess – IRS announces plan to delay application of Section 987 FX regulations for additional year -- IRS will give US W/H agents 60 days following issuance of IDR to cure accounts – IRS soon to release final FATCA regulations for FFI ‘sponsors’ – IRS will issue two sets of guidance for TCJA’s new Section 1446(f)

A review of the week's major US international tax-related news. In this edition: IRS announces Section 965 transition late-payment penalty and filing relief -- US officials offer more insights on upcoming international TCJA guidance – US taxpayers with high-risk transfer pricing and PE issues that participate in OECD’s ICAP may face IRS exam – IRS to deploy portal for FATCA certifications by late July, early August

A review of the week's major US international tax-related news. In this edition: White House official confirms ‘phase 2’ tax reform discussions with Congressional tax writers – US, Croatia considering tax treaty – OECD issues first peer report on BEPS Action 13 -- EU Council adopts Directive on new mandatory reporting of cross-border reportable arrangements.

A review of the week's major US international tax-related news. In this edition: US House Republicans, Trump Administration discussing framework for ‘phase two’ tax reform -- Final anti-corporate inversion regulations may be out in June -- IRS LB&I reviewing ongoing compliance campaigns in light of TCJA -- Updated UN Model Tax Treaty released.

A review of the week's major US international tax-related news. In this edition: Acting IRS Commissioner talks at May 2018 ABA Section of Taxation meeting about guidance projects implementing the TCJA – Treasury and IRS officials also address several tax reform related issues at the Meeting – IRS official reports IRS considering whether potential regulations under Section 267A should prevent the denial of deductions when a hybrid instrument or entity is not the cause of preferential treatment of relevant income – US District Court dismisses taxpayer’s suit against IRS in transfer pricing dispute.

A review of the week's major US international tax-related news. In this edition: US OMB Office of Regulatory Affairs provides insight into scope and release of TCJA international tax regulations – US House Ways and Means Committee to hold hearings on economic effects of tax reform – IRS announces plans to issue regulations expanding exception to Section 956(c) US property -- OECD considering revising Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: US House tax chairman floats “Tax Reform 2.0” – TCJA Technical Corrections unlikely in 2018 – IRS comments on interpreting new Section 163(j) -- OECD may up release consensus blueprint on digital economy to 2019.

A review of the week's major US international tax-related news. In this edition: Treasury and IRS officials offer TCJA international tax insights -- Final FATCA regulations close to release – Tax professor to advise on OMB/Treasury tax regulation agreement – US, Indonesia release MOU on CbC reporting – US and Costa Rica sign new TIEA.

A review of the week's major US international tax-related news. In this edition: European Union continues deliberations on elements of US tax reform – OECD Tax Director comments on US tax reform

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:US takes issue with EU digital tax proposals – EU to consider putting US on tax haven blacklist – US IRS issues FATCA publications

A review of the week's major US international tax-related news. In this edition:EU, OECD address digital taxation -- US strongly opposes taxes on digital economy – IRS to issue consolidated group guidance re: new Sections 965 and 163(j) in early April – IRS considering GILTI in context of US foreign tax credit regime – OECD releases new report on PE attribution of profits – OECD MLI will enter into force 1 July 2018

A review of the week's major US international tax-related news. In this edition: Congressional Republicans, Trump Administration mull “phase 2” tax reform – Joint Committee on Taxation working on tax reform “bluebook,” identifying technical corrections – IRS released FAQs on Section 965 repatriation transition tax – Final anti-corporate inversion regulations completed -- OECD released Interim Report on tax challenges from digitalization.