Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Congress to reconvene after Labor Day – Treasury and IRS hope to finish guidance projects before Obama administration ends – Treasury Deputy Assistant Secretary (International Tax Affairs) Robert Stack notes there are four main areas where Section 385 regulations could have unintended results-- Andrew Hickman former head of the OECD’s transfer pricing group, speaks at National Association for Business Economics Transfer Pricing Symposium in Washington.

A review of the week's major US international tax-related news. In this edition: IRS holds hearing on Proposed Section 385 debt/equity regulations -- OECD to present criteria to identify uncooperative jurisdictions for tax transparency purposes – Multilateral instrument to be opened for signature by end of 2016 -- Additional OECD BEPS discussion drafts coming.

A review of the EPS 's major US international tax-related news. In this edition: Treasury officials brief members of Congress on Proposed Section 385 debt/equity regulations – IRS issues proposed Qualified Intermediary Agreement – OECD releases BEPS documents for public comment.

A review of the week's major US international tax-related news. In this edition: US releases final country-by-country (CbC) reporting regulations – House W&M Republicans request comment period extension for Proposed Section 385 debt/equity regulations; Treasury remains firm – House tax reform blueprint details to be filled in; House Democrats take aim – OECD releases more guidance on CbC reporting.

A review of the week's major US international tax-related news. In this edition: House Tax reform blueprint released -- Treasury and IRS set 14 July hearing on Proposed Section 385 debt/equity regulations – House Ways and Means Democrats comment on Proposed Section 385 regulations -- US, Luxembourg announce plans to modify triangular provision in tax treaty -- UK votes for Brexit; major consequences including in regard to taxation.

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A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Democrats to target corporate inversions – US, EU continue dispute over EU state aid investigations – G-20 to promote tax certainty in wake of BEPS project -- Treasury ponders further changes to Proposed Section 385 debt/equity regulations – US Tax Court holds for taxpayer in nearly $1.36 billion transfer pricing case.

A review of the week's major US international tax-related news. In this edition: US House tax reform blueprint will cover international, business and individual reform – Treasury not inclined to delay finalization of Prop. Section 385 debt/equity regulations – Treasury will offer optional CbC reporting for 2016 -- Temporary and proposed withholding regs implementing IRS Notice 2015-10 expected soon – OECD draft requests input on multilateral instrument.

A review of the week's major US international tax-related news. In this edition: House tax leader says proposed Section 385 debt/equity regulations punitive and make US less competitive – Upcoming House tax reform blueprint will include framework for international tax reform – House Ways and Means members fine-tuning innovation box proposal -- Senate Finance Committee holds second hearing on corporate integration – Bipartisan Senate tax leaders again urge Administration to take action on EU state aid investigations – ECOFIN agrees to general approach regarding EU Anti-Tax Avoidance Directive.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee holds corporate integration hearing – Sen. Wyden releases comprehensive derivatives taxation draft – House Ways and Means Tax Policy Subcommittee Chair says US international reform remains a priority -- Treasury Secretary Jack Lew called on Congress to allow reciprocal exchange of information under FATCA.

A review of the week's major US international tax-related news. In this edition: A review of the week's major US international tax-related news. In this edition: Proposed Section 385 regulations a primary focus at recent ABA Section of Taxation meeting and PLI conference – Recent US model treaty also a topic at ABA meeting – House Ways and Means Tax Policy Subcommittee holds hearing to discuss ideas for broader tax reform – Senate Finance Committee Chairman Orrin Hatch to hold hearing to discuss corporate integration.

A review of the week's major US international tax-related news. In this edition:House comprehensive tax reform blueprint to be released end of June – Senate Finance holds business tax reform hearing – Treasury still considering whether to expand limits to post-inversion planning beyond inverter companies – US government to allow optional CbC reporting for 2016 to resolve gap year issue -- New IRS Associate Chief Counsel (international) lists top international guidance priorities – IRS notice with new draft 2017 qualified intermediary agreement coming.

A review of the week's major US international tax-related news. In this edition:Direction of US House international tax reform draft uncertain – Senate Finance Committee Chairman calls for comprehensive tax reform to curb corporate inversions – Senate corporate integration proposal will be revenue neutral -- New US anti-inversion rules, debt equity regulations may not be finalized at same time.

A review of the week's major US international tax-related news. In this edition: European Commission proposes Directive for public CbC reporting of tax information – Top EU official discusses State Aid investigations with US officials -- Draft Finance Committee corporate integration plan may include nonrefundable 35% withholding tax on interest payments and dividends – House and Senate introduce identical technical corrections bills – IRS proposed regulations address Section 305(c) deemed distributions and related withholding.

A review of the week's major US international tax-related news. In this edition: US government issues anti-corporate inversion regulations – Treasury and IRS release far-reaching proposed earnings-stripping rules.

A review of the week's major US international tax-related news. In this edition: US soon will issue proposed regulations to treat foreign-owned single-member LLCs as corporations, solely for reporting under Section 6038A – IRS updates list of countries for automatic exchange of tax info on bank interest paid to NR aliens – IRS issued annual report on APAs – House Ways and Means Subcommittee announces tax reform hearing 13 April.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee reviewing base erosion issues in crafting international tax reform draft – US tax reform window in 2017 – IRS final outbound asset reorganization regulations released – OECD issued consultation document under BEPS Action 6.

A review of the week's major US international tax-related news. In this edition: US international tax reform draft delay – Technical Corrections to Path Act coming soon; FIRPTA corrections not expected – OECD peer review process to monitor resolution of MAP cases "well advanced".

A review of the week's major US international tax-related news. In this edition: US Treasury reviewing Section 891 in context of EU State aid investigations – Treasury Secretary says legislation necessary to stem corporate inversions – US will cancel sharing of CbC reports with any country that publicly discloses data.

A review of the week's major US international tax-related news. In this edition: US to finalize CbC reporting regulations by 30 June – EU denies targeting US multinationals in State aid investigations – US removes Cuba from list of countries denying foreign tax credits, CFC deferral -- IRS issues Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities (2016).