Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says Republican tax reform plan will include border adjustability – Upcoming IRS LB&I audit campaign will include both inbound and outbound international tax issues -- Pending cross-border partnership transfer regulations will be effective for transfers occurring on or after 6 August 2015 – IRS Notice 2017-07 modifies effective date of deferral rules of Reg. Section 1.987-12(T).

A review of the week's major US international tax-related news. In this edition: Congressional Republican leaders offer insights into plans for US tax reform – IRS issues final regulations under Section 367 – Final Section 6038A regulations released.

A review of the week's major US international tax-related news. In this edition: Congress ends lame-duck session without Tax Technical Corrections – IRS issues Section 901(m) regulations limiting creditability of foreign taxes following covered asset acquisitions – IRS releases long-awaited regulations under Section 987 – IRS posted draft Form 8975, Country-by-Country Report, on IRS website.

A review of the week's major US international tax-related news. In this edition: President-elect Donald Trump names Steven Mnuchin as next Treasury Secretary -- House Ways and Means Committee Chairman offers details on development of a tax reform package – US, India reach agreement on first bilateral APA – OECD releases text of multilateral instrument under BEPS Action 15.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans bullish on prospects for US tax reform in 2017 – IRS to issue FATCA regulations package soon.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame-duck session following elections – Chances for comprehensive US tax reform improve – Treasury officials offer update on pending international guidance – Treasury looking at method for investment funds to prove US beneficial ownership for tax treaty purposes.

A review of the week's major US international tax-related news. In this edition: US election increases chances of comprehensive tax reform in 2017.

A review of the week's major US international tax-related news. In this edition: IRS issues package of Subpart F regulations – US to share summaries of unilateral APAs with foreign governments, following OECD BEPS recommendations.

A review of the week's major US international tax-related news. In this edition: US officials offer more insights into recent Section 385 debt/equity regulations – New FATCA Form W-8BEN-E required beginning 1 January 2017 -- Regulation package on Section 871(m) dividend equivalent payments and withholding rules coming, but not before mid-November.

A review of the week's major US international tax-related news. In this edition: Final and Temporary Section 385 debt/equity regulations significantly narrow scope of earlier proposed rules – US officials offer insights on Section 385 regulations – US government to focus on cross-border intangible property transfers for partnerships and corporations -- US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation if requirements met – OECD announces establishment of automatic info exchange relationships, global review of MAP programs.

A review of the week's major US international tax-related news. In this edition: Obama Administration issues final and temporary debt/equity regulations under IRC Section 385 – OECD held public consultations on two discussion drafts: Additional Guidance on Profit Attribution to PEs and Revised Guidance on Profit Splits.

A review of the week's major US international tax-related news. In this edition: Final Section 385 debt/equity regulations sent to White House Office of Information and Regulatory Affairs for review -- House Ways and Means Committee Republicans again urge Administration to delay finalizing Section 385 regulations – US Treasury official strongly criticizes EU State aid investigations – EY global survey finds increasing audits and more aggressive enforcement from tax authorities around the world.

A review of the week's major US international tax-related news. In this edition: Congress adjourns until after November election; lame duck session expected – US, Argentina to begin tax treaty negotiations – IRS: Inbound asset reorganization in which US Parent acquired substantially all transferred corp’s assets terminated GRA -- OECD final report on BEPS Action 14, Make Dispute Resolutions Mechanisms More Effective, to be released soon – OECD announces agreement in principle on Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: US government reaction to EU State aid investigations – House speaker expects tax reform in 2017 – IRS official predicts avalanche of MAP cases.

A review of the week's major US international tax-related news. In this edition: Congress returns from summer recess to short pre-election session – Treasury Secretary to meet with House Ways and Means Committee members on Prop. Section 385 debt/equity regulations – IRS issues Rev. Proc. 2016-46 providing foreign insurance guidance.

A review of the week's major US international tax-related news. In this edition: European Commission finds Ireland granted illegal State aid and orders recovery – US, Canada informally discussing joint audits – Congress returns to session after Labor Day.

A review of the week's major US international tax-related news. In this edition: Congressional Republican tax writers reiterate concerns over proposed Section 385 debt/equity regulations – US Treasury releases White Paper on European Commission's State aid investigations -- Ireland announces tax treaty talks with United States -- OECD releases discussion draft on branch mismatch structures under BEPS Action 2.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issued 2016-2017 Priority Guidance plan – IRC Section 5000(c) final regulations released on 2-percent excise tax on US government payments to foreign persons -- Treasury official confirms Administration can address unintended consequences in Proposed Section 385 debt/equity regulations.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Chairman comments on lawsuit against anti-corporate inversion regulations – US presidential candidates talk tax plans – ABA Section of Taxation submits comments on cloud computing.

A review of the week's major US international tax-related news. In this edition: US Treasury official says no set deadline for finalization of Section 385 debt/equity regulations – US, Singapore announce plans for reciprocal FATCA IGA with automatic info exchange, TIEA -- IRS announces IGAs not in force on 1 January 2017 will not be treated as in effect – US Chamber of Commerce files lawsuit challenging validity of anti-corporate inversion regulations.