Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Congress passes temporary stopgap spending measure to facilitate omnibus bill negotiation; Tax Title uncertain – IRS releases Rev. Ruling 2022-43 with final qualified intermediary   withholding agreement – IRS issues proposed regulations on single-entity treatment of consolidated groups for purposes of Section 951 – FinCEN further extends FBAR filing deadline – FinCEN issues proposed regulations on beneficial ownership – OECD releases consultation document on Amount B of BEPS 2.0 Pillar One – EU adopts Directive on global minimum tax.

A review of the week's major US international tax-related news. In this edition: US Congress grapples with government funding in lame duck, will impact tax package options – US, Croatia sign tax treaty – OECD releases consultation document on design elements of BEPS Pillar One Amount B re: simplification of transfer pricing rules.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame duck session; business tax measures could be included in omnibus spending bill – IRS Corporate Alternative Minimum Tax guidance possible before year-end.

A review of the week's major US international tax-related news. In this edition: IRS pivoting to cryptocurrency, opens digital asset project office – IRS drafting questions on cryptocurrency, digital assets for corporate and partnership returns.

A review of the week's major US international tax-related news. In this edition: Republicans take House, Democrats hold Senate; lame-duck legislation remains uncertain – IRS issues highly anticipated foreign tax credit proposed regulations – IRS proposed regulations under Section 367(d) will be released early next year – IRS considering use of economic substance in transfer pricing audits, even with TP documentation.

A review of the week's major US international tax-related news. In this edition: US congressional lame duck tax legislation unclear amid midterm election uncertainty – Proposed foreign tax credit regulations coming soon, limited CAMT guidance this year – IRS releases 2022-2023 Priority Guidance Plan – Congressional ranking Republicans urge reversal of decision to terminate US-Hungary tax treaty – Biden Administration nominates new IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Treasury warns there may be little guidance re new corporate minimum tax and stock buyback tax before effective date – No transition period or delay in implementation date for final Section 1446(f) withholding regulations – IRS expects more penalties in transfer pricing cases – House Ways and Means Committee Republicans request Treasury retain all documents, communications re OECD BEPS 2.0 Pillar One Agreement.

A review of the week's major US international tax-related news. In this edition: US Treasury working on ‘prophylactic’ measures to address new tax regimes in the context of future tax treaties – US, Croatia to sign tax treaty before year-end – Treasury official expects proposed crypto regulations release in 2022 – OECD wants broad acceptance of its Crypto Asset Reporting Framework.

A review of the week's major US international tax-related news. In this edition: IRS proposed foreign tax credit regulations ‘weeks away’ – 2006 proposed PTEP regs officially withdrawn, new regs in first half of 2023 – IRS official offers update on new corporate alternative minimum tax – IRS plans to reconsider APA revenue procedure guidance in light of recent Eaton Corporation decision.

A review of the week's major US international tax-related news. In this edition: OECD releases new global tax transparency framework for crypto-assets, amendments to Common Reporting Standard – IRS to request Sponsoring Entities cancel their FATCA agreement if they fail to meet Sponsoring Entity requirements.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework on BEPS releases new consultation on Pillar One Amount A, other BEPS related documents – OECD will release amendments to crypto-asset reporting framework, Common Reporting Standard on 10 October.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund federal government, recesses until after midterm elections – EY comments on Inflation Reduction Act’s CAMT in M&A context – FinCEN issues final beneficial ownership rule – OECD’s FTA issues bilateral APA manual.

A review of the week's major US international tax-related news. In this edition: House Republican leadership set to release “Commitment to America” platform – IRS provides guidance on applying noncompulsory payment rules in FTC regs to amended tax decrees between MNEs and Puerto Rico tax authority – IRS officials offer updates on international issues and regulations.

A review of the week's major US international tax-related news. In this edition: US Congress focused on CR to extend government funding beyond 30 September; post-midterm year-end bill could address tax – House Republicans poised to release “Commitment to America” November election platform – OECD holds public consultation on Progress Report on BEPS Pillar One Amount A.

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-midterm election session – Treasury official offers international regulatory update; PTEP regs coming in Q1 2023 – US tax treaty negotiations with Switzerland, Israel to begin; pending treaties being updated – 6th Circuit rules IRS bears burden of proof to cancel APAs – OECD considering two permanent safe harbors re BEPS 2.0 Pillar Two global minimum tax rules – OECD’s Pascal Saint Amans to step down.

A review of the week's major US international tax-related news. In this edition: IRS Notice 2022-36 penalty relief applies to certain international tax information returns – OECD releases public comments on Progress Report on Amount A of BEPS Pillar One – EY concludes Amount A of Pillar One will result in a few mature market jurisdictions gaining additional taxing rights, but most others receiving little benefit.

A review of the week's major US international tax-related news. In this edition: IRS to delay effective date for aspects of Section 871(m) regulations, further extend transition relief – IRS extends deadline for unfiled 2019 and 2020 returns, penalty relief for certain 2019 and 2020 returns – US Tax Court increases Medtronic royalty rate under unspecified TP method.

A review of the week's major US international tax-related news. In this edition: President Biden signs Inflation Reduction Act of 2022 into law; includes new 15% corporate alternative minimum tax – Inflation Reduction Act includes unprecedented energy and climate provisions – Stock buyback provision in Inflation Reduction Act may have broader implications – IRS funding in Inflation Reduction Act may increase scrutiny of transfer pricing cases – Treasury and IRS to extend applicability date of 2016 final Section 987 FX regulations additional year.

A review of the week's major US international tax-related news. In this edition: Senate approves Inflation Reduction Act of 2022 – President Biden signs CHIPS and Science Act.

A review of the week's major US international tax-related news. In this edition: US Senate Democrats reach agreement on health, climate and tax budget reconciliation bill; moves to Senate floor 6 August – House Ways and Means Committee Republicans introduce resolution to compel Treasury to produce documents showing effects of BEPS 2.0 Pillar One rules.