Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans consider plans for budget reconciliation bills in 2025 – Congress must pass government funding by 20 December, US-Taiwan tax bill still possible – IRS issues final and proposed FX regulations – US-Norway CAA released – IRS requests comments on APA and mutual agreement procedures.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans consider budget reconciliation options to enact legislative agenda – Congress to address government funding that expires on 20 December 2024 – President-elect Trump nominates new IRS Commissioner – IRS releases long-awaited PTEP proposed regulations – Cyprus clarifies exchange of CbC reports with US.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump nominates Treasury Secretary, fills out economic team G20 Leaders’ Declaration addresses international tax and BEPS 2.0 project OECD Global Forum on Transparency / Information Exchange announces 61 jurisdictions joining CARF

A review of the week's major US international tax-related news. In this edition: Congressional Republicans eye two budget reconciliation bills in 2025 to enact tax legislation – OECD holds Tax Certainty Day, releases 2023 MAP and APA statistics.

A review of the week's major US international tax-related news. In this edition: Republican US election sweep likely means TCJA extension via reconciliation, BEPS 2.0 project uncertainty – Final IRS Section 987 FX gain / loss regulations release before year-end – IRS comments on new passthrough field unit organization – IRS will permit digital asset transaction reporting on schema, not IRS Form 1042-S – IRS official says companies that ignored TP compliance letters referred for examination.

A review of the week's major US international tax-related news. In this edition: US 2024 election to have major impact on US tax policy – IRS to issue PTEP, Section 987 FX guidance by year-end – US to release notice on voluntary “Amount B”.

A review of the week's major US international tax-related news. In this edition: US announces tax agreement negotiations with Taiwan – IRS launches new LB&I pass-through field operations unit, EY’s Jeff Erickson chosen to lead – IRS announces new FATCA relief for FFIs – US officials discuss coming changes to CAMT regs – IRS official recommends expanding OECD Treaty Article 25 MAP scope – OECD official offers BEPS IF update.

A review of the week's major US international tax-related news. In this edition: US House legislators urge Taiwan tax negotiation – IRS launches new LB&I passthrough field operations unit – IRS official discusses CAMT campaign – OECD releases tax report to G20 Finance Ministers and Central Bank Governors.

A review of the week's major US international tax-related news. In this edition:  Congress out of session until mid-November despite calls to reconvene and pass necessary funding measures – Upcoming election too close to predict for both presidential and congressional races – 2024 Annual Meetings of the IMF and World Bank Group to take place in Washington next week – IRS releases AM 2024-002 addressing application of Section 246(b) limitation to deductions under Sections 243, 245 and 250 – Italy and France propose changes to their digital services taxes, potentially increasing tax burdens on technology companies.

A review of the week's major US international tax-related news. In this edition:  IRS releases final IP repatriation regulations – Treasury and IRS will release technical corrections to CAMT regs – IRS final DCL regulations will clarify anti-avoidance rule – OECD issues working paper on tax arbitrage through closely held businesses.

A review of the week's major US international tax-related news. In this edition:  US general election will have major impact on tax policy IRS to update draft digital asset reporting instructions for Form 1099-DA OECD issues FAQs on CARF EY releases comprehensive analysis of proposed CAMT regs 

A review of this week's major US international tax-related news. In this edition:  US presidential candidates reveal tax positions – Congress averts government shutdown with continuing resolution, adjourns until after election – US officials discuss CAMT – Digital asset noncustodial broker reporting guidance coming before year end – Puerto Rico initiates public consultation on BEPS 2.0 GloBE rules – OECD holds signing ceremony for BEPS Pillar Two Subject to Tax Rule Multilateral Instrument.

A review of this week's major US international tax-related news. In this edition:  US House Speaker promises “Day One” focus on corporate tax policy with Republican election sweep – IRS soon to release final Section 367(d) regs on IP repatriation – IRS final Section 987 FX regs to reserve on partnership issues – IRS guidance on BEPS Pillar One Amount B coming before year end – IRS official clarifies ‘disregarded payment loss’ rules effective date in recent DCL regs – IRS soon to release guidance on MAP and APA program – IRS assembling CAP transfer pricing team – OECD issues seventh annual BEPS Action 13 CbCR peer review report.

A review of this week's major US international tax-related news. In this edition:  US Treasury issues proposed regulations on CAMT, extends penalty relief for failure to pay estimated CAMT – Treasury and IRS officials to evaluate narrowing scope of future anti-partnership basis-shifting guidance – Official offers international regulatory update – OECD releases standardized ICAP template for tax administration outcome letters – OECD to address incentives that undermine BEPS Pillar Two GloBE rules.

A review of this week's major US international tax-related news. In this edition:  US Congress to return to Washington – IRS corrects proposed regs to permit foreign currency mark-to-market election to be made with returns filed after 19 August 2024 – USTR requests dispute settlement consultations with Canada under USMCA to address recent enactment of Canadian DST.

A review of this week's major US international tax-related news. In this edition:  US Tax Court rules taxpayer entitled to DRD, but limits foreign tax credit.

A review of this week's major US international tax-related news. In this edition:  IRS issues new proposed regulations that limit / modify taxpayers’ FX elections – UN Committee advances Terms of Reference for convention on international tax cooperation.

A review of this week's major US international tax-related news. In this edition:  US economic and tax policy become focus in Presidential race – IRS issues early draft form for brokers to report digital assets sales and exchanges – IRS expanding Compliance Assurance Process program to privately held corporations, including foreign-owned – OECD releases transfer pricing framework for lithium.

A review of this week's major US international tax-related news. In this edition:  US Treasury and IRS issue proposed DCL regs addressing BEPS Pillar Two, other issues.

A review of this week's major US international tax-related news. In this edition:  US Congress adjourns for August recess – Senate fails to move Tax Relief for American Families and Workers Act with international provisions – G20 / Central Bank Governors communiqué reiterates support for BEPS 2.0 project