Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US international tax reform takes center stage in Congress -- Treasury will not renegotiate pending tax treaties and protocols following release of new US Model treaty -- IRS files appeal in Altera Corp. v. Commissioner – IRS issues final regulations under Code Section 6038D.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to begin drafting international tax reform legislation immediately – Newly revised US Model Income Tax Treaty released – Treasury official comments on EU State Aid investigations.

A review of the week's major US international tax-related news. In this edition: President Obama releases FY 2017 Budget – Treasury Secretary Lew testifies before two Congressional tax-writing committees on President's FY 2017 budget proposal – Special counsel to IRS associate chief counsel (international) John Merrick talks about anti-inversion guidance at PLI conference in NYC – Former EY national director of International Tax Services Margie Rollinson is named new IRS associate chief counsel (international).

A review of the week's major US international tax-related news. In this edition: House tax reform leadership forming – Treasury official delivers State Aid concerns to EU – IRS issues guidance on partnership allocations of creditable foreign tax expenditures under Section 704 – Treasury poised to release updated US Model Tax Treaty – IRS to accept bilateral APA applications with India beginning 16 February.

A review of the week's major US international tax-related news. In this edition: European Commission releases major anti-tax avoidance package -- 31 countries sign Multilateral Competent Authority Agreement for automatic exchange of CbC reports -- Senate Finance Committee draft corporate integration plan could be developed within a few months – US anti-inversion regulations to be released soon .

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee reviewing options for corporate tax integration – House Ways and Means to hold hearings on inversions, repatriation in 2016; names Chief Tax Counsel – IRS Notice 2016-10 announces forthcoming regulations on RICs’ foreign tax refunds.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says international tax reform bill mark-up coming in 2016 – President Obama delivers final State of the Union Address – US Treasury considering a foreign goodwill exception in final Section 367 regulations.

A review of the week's major US international tax-related news. In this edition: Congress returns to session; international tax reform under discussion – US MNC will owe $86 million in withholding tax, plus interest, in stipulated Tax Court decision – Sixth Circuit reverses Tax Court, concludes FX option can qualify as foreign currency contract.

A review of the week's major US international tax-related news. In this edition: IRS will no longer apply 1% excise tax to retrocession agreements between two foreign reinsurance companies – Congressional tax leader introduces bill to delay US country-by-country reporting until 2017.

A review of the week's major US international tax-related news. In this edition: US releases proposed country-by-country (CbC) reporting regulations – House tax leader says international tax reform next on the agenda – More upcoming international tax guidance coming.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation – Treasury officials offer insights on tax treaty negotiations, anti-corporate inversion guidance and EU state aid investigations.

A review of the week's major US international tax-related news. In this edition: Temporary tax extenders legislation on hold pending Congressional negotiations over more comprehensive package – IRS official previews upcoming international tax guidance.