Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary pressed on how to pay for tax reform – Congressional supporters of border adjustability proposal not giving up – OMB Director says Administration does not necessarily support deficit neutral tax reform.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means tax reform hearing focuses on border adjustability -- Senate Majority Leader expresses optimism for US tax reform -- Trump Administration releases $4.094 trillion FY 2018 Budget blueprint.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee held first hearing on tax reform in new Congress – W&M hearing on border adjustability proposal scheduled for 23 May – Trump Administration to release FY’18 Budget on 23 May -- US Treasury has begun review of final, temporary and proposed tax regulations issued after 1 January 2016 – Treasury moving tax regulations consistent with ‘freeze’ order -- US in tax treaty discussions with Ireland, Luxembourg, Netherlands, Argentina and Colombia.

A review of the week's major US international tax-related news. In this edition: Trump Administration officials discuss tax reform with Republican Senate Finance members – President Trump comments on border adjustability, suggests 10% repatriation rate – House Ways and Means Committee to hold tax reform hearing on 18 May – Trump Administration nominates Dave Kautter as Treasury Assistant Secretary for Tax Policy.

A review of the week's major US international tax-related news. In this edition: President Trump says Administration’s tax reform plan is open to negotiation – House Republican goal now to develop single tax reform proposal palatable to both Administration and Congress – US Treasury making progress in negotiating competent authority agreements to exchange CbC reports -- OECD released update on exchange relationships for exchanging CbC reports.

A review of the week's major US international tax-related news. In this edition: Trump Administration releases tax reform plan -- President Trump signs Executive Order to review significant tax regulations issued since 1 January 2016 – US Tax Court rules modification of variable prepaid forward contracts does not trigger gain realization – IRS files notice of appeal in Medtronic transfer pricing case.

A review of the week's major US international tax-related news. In this edition: Trump Administration confirms tax reform in 2017 – White House to release tax reform plan “very soon” – Treasury may resume issuing tax regulations – President to sign Executive Order to review significant tax regulations issued in 2016.

A review of the week's major US international tax-related news. In this edition: Trump Administration to return to ACA repeal, then tax reform.

A review of the week's major US international tax-related news. In this edition: US tax reform, another health care deal dominated discussions before Congressional recess – IRS extended deadline for submitting QI, foreign withholding partnership, and foreign withholding trust agreement renewal requests -- IRS APMA issued 18th annual Advance Pricing Agreement report –- OECD released updated guidance on Country-by-Country Reporting.

A review of the week's major US international tax-related news. In this edition: President Trump and Congressional Republicans pivot to tax reform following ACA repeal failure – UK triggers Brexit; sets stage for complex negotiations with EU.

A review of the week's major US international tax-related news. In this edition: TUS House Ways and Means Committee Chairman expects Blueprint’s border adjustability proposal will be included in US tax reform; but with phase-in and modifications – IRS to resume issuing “sub-regulatory” guidance – US Tax Court rules for Amazon.com, Inc., in transfer pricing cost sharing case – Country-by-Country Reporting update.

A review of the week's major US international tax-related news. In this edition: Tax reform takes backseat as Congress focuses on health care reform – Senate Majority Leader less optimistic for completing tax reform by August recess – Treasury official expects government to resume issuing tax guidance sooner, rather than later.

A review of the week's major US international tax-related news. In this edition: President Trump delivers address to Congress; US tax reform remains a priority – IRS issues draft instructions for new Form 8975, Country by Country Report, and accompanying Schedule A, Tax Jurisdiction and Constituent Entity Information.

A review of the week's major US international tax-related news. In this edition: President Trump holds meeting with CEOs of major retailers to discuss tax reform and border-adjustable tax proposal – Congressman Mike Kelly calls for a more methodical approach in trying to pass tax reform legislation to impose a border-adjustable tax – IRS official at recent International Tax Institute luncheon notes proposed Section 901(m) regulations include broader language than the original statute because they are meant to act as a catchall for transactions not targeted by Section 901(m) – IRS official at recent New York conference indicates the IRS will not be releasing any guidance other than most routine ones in the near future; practitioners caution that consolidated group members should ensure that they satisfy the Section 385 debt-equity documentation requirements – Steven Mnuchin sworn in as 77th US Treasury secretary.

A review of the week's major US international tax-related news. In this edition: President Trump to release comprehensive tax reform plan in coming weeks -- Japan confirms US limited partnership is fiscally transparent for Japanese tax purposes when applying US-Japan treaty.

A review of the week's major US international tax-related news. In this edition: US Senate will conduct its own tax reform process, not simply accept House bill -- IRS LB&I releases new compliance initiatives, including 3 international tax areas.

A review of the week's major US international tax-related news. In this edition: Donald Trump assumes the US presidency; comprehensive tax reform a priority – Final anti-corporate inversion regulations released – IRS issues temporary regulations denying nonrecognition treatment for contributions of appreciated property to partnerships with foreign partners – IRS issues final dividend equivalent rules – IRS Rev. Proc. 2017-23 provides details on CbC voluntary reporting.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Republicans finalizing open issues in Tax Reform Blueprint – OECD releases BEPS Action 6 Discussion Draft on treaty entitlement of non-CIV funds.

A review of the week's major US international tax-related news. In this edition: Tax reform and Obamacare repeal top Republican agenda as Congress returns to Washington – IRS releases extensive FATCA-related guidance.

A review of the week's major US international tax-related news. In this edition: Congress returns for 115th Congress and US tax reform debate – IRS issues final PFIC regulations – US, Argentina sign Tax Information Exchange Agreement.