Ey Cross-border Taxation Alerts

A review of this week's major US international tax-related news. In this edition:  US House begins summer recess, Senate has additional week – DC Circuit Court of Appeals reverses Tax Court; FP’s gain from inventory on US partnership disposition is foreign-source – IRS official comments on pending CAMT guidance – PTEP regulations in the ‘home stretch.’

A review of this week's major US international tax-related news. In this edition:  US IRS releases final Section 367(b) regs addressing cross-border triangular reorganizations, inbound nonrecognition transactions – Congress reacts to Supreme Court’s Loper Bright decision invalidating Chevron – OECD Inclusive Framework close to finalizing MLC text on Pillar One Amount A, expanded Amount B framework.

A review of the week's major US international tax-related news. In this edition: IRS issues procedural final regulations on stock repurchase excise tax – IRS releases final digital asset broker reporting regs, transitional relief for certain brokers – Canada’s DST in force, US legislators react – OECD releases draft BEPS 2.0 User Guide for GloBE information return XML Schema.

A review of the week's major US international tax-related news. In this edition: US Supreme Court ends court deference to agency interpretations of ambiguous laws, including tax laws – US House Republican Tax Team on global competitiveness to hold first field meeting with stakeholders on 8 August, White Paper to follow – IRS will address DCL income allocation rules in context of BEPS Pillar Two global minimum tax jurisdictional tax blending – US, Switzerland sign new FATCA Model 1 agreement – US Treasury and OECD officials offer insights on BEPS 2.0 Pillar One and Pillar Two project.

A review of the week's major US international tax-related news. In this edition: US Supreme Court upholds validity of IRC Section 965 mandatory repatriation tax – US Treasury Department suspends key provisions of US-Russia Tax Treaty and Protocol – IRS issues package on certain related-party partnership basis shifting transactions – OECD/G20 Inclusive Framework releases documents on BEPS Pillar One Amount B and Pillar Two.

A review of the week's major US international tax-related news. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – IRS again extends penalty relief for failure to pay estimated CAMT.

A review of the week's major US international tax-related news. In this edition: US IRS officials discuss pending CAMT, stock buy-back regs – BEPS Pillar One Amount B package to be finalized soon – OECD releases updated FAQs on ICAP program.

A review of the week's major US international tax-related news. In this edition: OECD will release two more rounds of BEPS Pillar Two GloBE administrative guidance – US will not sign Pillar One MLC until India and China agree to unresolved transfer pricing issues.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee launches new TCJA public comment portal – US opposes annual billionaire global wealth tax proposal – IRS notice extends Section 871(m) transition relief for dividend equivalent transactions – IRS to defer applicability date of some provisions in Sections 59A and 6038A regs for qualified derivative payments – Section 6045 final crypto reporting regulations coming in 2024 – OECD committed to open BEPS Pillar One multilateral convention for signature in June – Work continuing to finalize BEPS Pillar One Amount B provisions.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Chair working with Majority Leader to bring tax bill to Senate floor – CBO releases new revenue estimate on TCJA extension – White House National Economic Advisor offers insights into Biden Administration tax policy 

A review of the week's major US international tax-related news. In this edition: US Ways and Means Chairman says all current TCJA measures will be on the table in 2025 –  Treasury official says proposed regulations on CAMT in advanced stage.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing highlighted expiring TCJA, OECD BEPS – IRS updates rules for requesting PLRs on Section 355 transactions.

A review of the week's major US international tax-related news. In this edition: US tax policy lines being drawn ahead of 2024 election, TCJA ‘cliff’ – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – OECD releases consolidated GloBE commentary document, revised GloBE examples.

A review of the week's major US international tax-related news. In this edition: IRS waives penalty for failure to pay estimated CAMT – OECD BEPS 2.0 update: what’s coming – IESBA announces changes to its Tax Planning and Related Services project that will apply to all tax planning activities.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One Multilateral Convention on Amount A moving forward.

A review of the week's major US international tax-related news. In this edition: US Congress returns from spring recess; no movement on tax bill – IRS releases latest APA report – OECD misses deadline on BEPS Pillar One MLC on Amount A.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.

A review of the week's major US international tax-related news. In this edition: Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.

A review of the week's major US international tax-related news. In this edition: President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.

A review of the week's major US international tax-related news. In this edition: President Biden delivers State of the Union address, offers new tax proposals – US House Ways & Means Tax Subcommittee holds hearing on OECD BEPS Pillar 1 – OECD Secretary-General Tax Report offers insights on BEPS project.