Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: President Biden, congressional leaders in debt ceiling talks, but no breakthroughs yet – US Senate Finance Committee holds hearing on cross-border pharma manufacturers and US international tax policy – US government officials discuss CAMT guidance, another notice coming – New US-Israel tax treaty in the works – US, Swiss tax protocol negotiations progressing.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed regulations on IP repatriation subject to Section 367(d) – Bipartisan US senators introduce bill to authorize negotiations with Taiwan to conclude tax agreement – US, Norway conducting tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: US House passes debt ceiling, spending bill – Treasury says no decision on interim CAMT guidance – IRS updates crypto notice – OECD to release BEPS Pillar Two qualified domestic minimum top-up tax safe harbor by summer.

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans introduce debt limit, spending bill – SEC Chairman defends agency’s authority over cryptocurrency products.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess; will need to address debt ceiling and spending – IRS issues proposed rules on micro-captive transactions as listed transactions.

A review of the week's major US international tax-related news. In this edition: IRS will provide transition period for documentation requirements for FTC "single-country exception" – US Tax Court rules IRS lacks authority to assess penalties under Section 6038(b) – US, Germany sign competent authority arrangement on automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US’ OECD contribution.

A review of the week's major US international tax-related news. In this edition: IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary testifies before Senate Finance Committee on FY ‘24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira’s hyperinflationary status has US tax consequences.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

A review of the week's major US international tax-related news. In this edition: IRS will issue initial guidance on how far back to apply basis adjustments to arrive at “opening” books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US shareholder for Section 951(a)(2)(B) purposes.

A review of the week's major US international tax-related news. In this edition: IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

A review of the week's major US international tax-related news. In this edition: President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, ‘billionaire surtax’ – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs, competent authority assistance.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.

A review of the week's major US international tax-related news. In this edition: Rep. Kevin McCarthy new House Speaker, Rep. Joshua Smith named chairman of House Ways and Means Committee – IRS CAMT guidance addresses questions, leaves open issues.

A review of the week's major US international tax-related news. In this edition: IRS issues interim guidance on application of new corporate alternative minimum tax – IRS releases interim guidance on excise tax on certain corporate stock buybacks – IRS releases final regulations on FIRPTA tax exception for qualified foreign pension funds and qualified controlled entities.

A review of the week's major US international tax-related news. In this edition: US Congress passes $1.7 trillion spending bill; no Tax Title – Treasury plans guidance on CAMT and stock buyback excise tax by year-end – IRS announces it will issue proposed regulations amending final Section 1446(f) final withholding regulations for PTPs – Treasury official says GILTI will need to be reformed – Congressional Republican lawmakers voice concerns over BEPS Pillar Two Undertaxed Profits Rule – OECD issues (i) consultation document on Pillar One MLI re: DSTs; (ii) consultation document on Pillar Two GloBE information return; (iii) consultation document on Pillar Two tax certainty for GloBE rules; and (iv) guidance on Pillar Two safe harbors and penalty relief.