Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: IRS expands “no TIN” list to include foreign jurisdictions that offer TINS; Australia added to list – Treasury considering carving-out long-term bank loans from “cash or cash equivalents” in Section 965 transition tax -- EU requests OECD Forum on Harmful Tax Practices conduct “fast track” review of certain US tax reform provisions.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee Chairman expects series of small, technical corrections bills to TCJA -- House Ways and Means Tax Policy Subcommittee will hold hearing on tax extenders on 14 March – Senior Treasury tax official resigns.

A review of the week's major US international tax-related news. In this edition: US Treasury officials offer updates on TCJA international guidance -- IRS LB&I issued guidelines for delinquent Forms 1120-F, waiver requests – EU surveying European multinationals re: US tax reform.

A review of the week's major US international tax-related news. In this edition: US government issues more repatriation transition guidance in Rev. Proc. 2018-17 – Treasury officials offer insights on future international TCJA guidance – US to defend TCJA’s FDII provision as WTO-compliant – IRS taking leadership role in OECD’s International Compliance Assurance Program -- OECD released more BEPS Action 13 CbC reporting guidance

Updated US Treasury/IRS 2017 - 2018 Priority Guidance Plan issued with TCJA projects – Treasury to delay effective date of final Section 987 branch currency regulations to 2020 – US to begin tax treaty negotiations with Armenia

A review of the week's major US international tax-related news. In this edition: US Treasury addresses tax guidance for TCJA – Joint Committee on Taxation reviewing issues for TCJA technical corrections, but no date – ‘Off-year’ Blue Book on TCJA possible.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-13 – Treasury close to determining fate of Section 385 debt/equity regulations -- Treasury Secretary attempts to ease European concerns regarding US tax reform legislation.

A review of the week's major US international tax-related news. In this edition: US technical tax corrections bill on hold for now – IRS LB&I issues series of internal transfer pricing directives – IRS says taxpayers can elect mark-to-market method of accounting in recent Section 988 proposed regulations.

A review of the week's major US international tax-related news. In this edition: US Treasury grants further extension for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2018-07 on new transition tax – IRS suspends W/H obligations under new Section 1446(f) for certain publicly traded partnership interests – FASB to issue additional guidance on ASC 740, Income Taxes, re: provisions in Tax Cuts and Jobs Act -- US Tax Court rules 6-year limitations period in Section 6501 only applies for tax years to which Section 6038D foreign financial asset reporting requirement effective.

A review of the week's major US international tax-related news. In this edition: US tax reform has tax accounting implications; SEC offers financial statement reporting relief – EU voices concern over US tax reform’s international provisions.

A review of the week's major US international tax-related news. In this edition: US Congress passes landmark tax reform legislation, President Trump signs bill into law – House Republican tax leader says more US tax legislation coming – IRS issues proposed FX regulations – US, Spain sign CAA to exchange CbC Reports – IRS to appeal Grecian Magnesite Mining to DC Circuit Court of Appeals.

A review of the week's major US international tax-related news. In this edition: US tax reform bill finalized; Congress to vote week of 18 December -- US, France sign joint statement on exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House, Senate vote to go to conference committee to reconcile final tax reform bill – Transition period floated for tax reform international provisions – Repeal of ACA mandate may be included in final tax reform bill – Treasury official expects considerable “sub-regulatory guidance” after enactment of tax reform.

A review of the week's major US international tax-related news. In this edition: US Senate poised to pass US tax reform bill -- IRS may not complete bilateral CAAs by year-end for exchange of CbC reports -- IRS issues proposed regulations on international issues related to new partnership audit regime -- IRS rules GRA term fixed as of date of initial transfer -- US to appeal IRS violated APA regarding anti-inversion regulations.

A review of the week's major US international tax-related news. In this edition: US Senate to consider Finance Committee tax reform bill after Thanksgiving holiday – Congressional Republicans, Trump Administration officials aim to enact tax reform by year-end.

A review of the week's major US international tax-related news. In this edition:US House of Representatives approves comprehensive tax reform bill – US Senate Finance Committee reports out tax bill; consideration on Senate floor expected week of 27 November.

A review of the week's major US international tax-related news. In this edition:Congress moving forward on competing tax reform bills; action expected -- IRS announces 3 new international tax compliance campaigns -- OECD published updated Transfer Pricing Country Profiles.

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee releases comprehensive tax reform bill -- Treasury considering clarifications to ’F’ reorganization regulations -- US official suggests non-delta-one transaction rules in Section 871(m) dividend equivalent regulations may not take effect.

A review of the week's major US international tax-related news. In this edition:House approves Senate-passed FY 2018 budget resolution; Ways and Means Committee tax reform bill set for release 1 November, legislative markup to begin 6 November – Treasury official says Section 385 debt/equity regulations ‘overly burdensome’ and will be substantially amended – David Kautter, current Treasury Assistant Secretary for Tax Policy, also named Acting IRS Commissioner.