Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada’s DST proposal.

A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer “Alternative A” in scoping rules for Amount B in BEPS Pillar One

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and “promoters abusing tax rules on the books.” 

A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

A review of the week's major US international tax-related news. In this edition: US Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.

A review of the week's major US international tax-related news. In this edition: IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

A review of the week's major US international tax-related news. In this edition: Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

A review of the week's major US international tax-related news. In this edition: Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

A review of the week's major US international tax-related news. In this edition: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS 2.0 Pillars One and Two technical documents – House Ways and Means Tax Subcommittee hearing on BEPS sees Republicans criticize Biden Administration’s policy – IRS PTEP proposed regs on track for release later this year.

A review of the week's major US international tax-related news. In this edition: OECD releases outcome statement on BEPS 2.0 Pillars One and Two progress – US Congress considering action on a US-Taiwan tax agreement – US senators reissue crypto-assets legislative proposal, request more information – Joint Committee on Taxation issues digital asset report.

A review of the week's major US international tax-related news. In this edition: US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.

A review of the week's major US international tax-related news. In this edition: US Senate approves US-Chile income tax treaty – Congressional Joint Committee on Taxation releases revenue analysis of BEPS Pillar Two global minimum tax – BEPS Pillar One and Pillar Two developments expected in coming weeks.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee approves three separate tax packages – Proposed US-Chile income tax treaty may have final US Senate vote as early as 21 June – OMB’s OIRA will no longer review Treasury tax regulations – OECD officials comment on BEPS Pillars One and Two.  

A review of the week's major US international tax-related news. In this edition: Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.  

A review of the week's major US international tax-related news. In this edition: US Congress passes debt ceiling legislation – US House Ways and Means Committee Republicans introduce legislation targeting OECD BEPS 2.0 Pillar Two Undertaxed Profits Rule – US Senate Foreign Relations Committee reports out proposed US-Chile income tax treaty – US House members introduce resolution calling for legislation to prevent US-Taiwan double taxation.  

A review of the week's major US international tax-related news. In this edition: US House Republicans to introduce anti-BEPS Pillar Two legislation – G-7 Finance Ministers welcome OECD progress report, reiterate commitment to BEPS Pillars One and Two – IRS to hire additional transfer pricing and competent authority staff, will expand CAP, APA and pre-filing programs.

A review of the week's major US international tax-related news. In this edition: OECD official offers insights on BEPS Pillar One and Pillar Two – US Senate Foreign Relations Committee may act on proposed US-Chile tax treaty – IRS official clarifies coming PTEP regulations in regard to partnerships.