Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740 billion climate/energy, health and tax reconciliation bill – Congress passes $280 billion CHIPS and Science Act; goes to President for signature – IRS makes substantive changes to final US foreign tax credit regulations.

A review of the week's major US international tax-related news. In this edition: US budget reconciliation legislation uncertainty continues – Treasury confirms termination of US-Hungary tax treaty.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington following 4 July recess; Sen. Manchin will not support climate measures, tax increases in budget reconciliation following US inflation report – IRS releases proposed FX regulations – US plans to terminate US-Hungary tax treaty – OECD releases Progress Report on Amount A of Pillar One.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats continue to negotiate slimmed-down budget reconciliation bill – OECD officials provide BEPS 2.0 update at annual tax conference – US officials discuss BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin meet again to discuss budget reconciliation – US Supreme Court accepts FBAR case for review – IRS plans to expand transfer pricing audit coverage.

A review of the week's major US international tax-related news. In this edition: President Biden expresses confidence budget reconciliation bill will pass Congress; meetings held – Congressional Republicans propose anti-inflationary measures, including tax cuts – Republican House Ways and Means Committee members ask Treasury to delay final foreign tax credit regulations – OECD official urges ‘first-movers’ on BEPS 2.0 Pillar Two.

A review of the week's major US international tax-related news. In this edition: US Sen. Manchin says no deal yet on limited budget reconciliation bill – Treasury Secretary comments on BEPS Pillar One – Treasury official offers insights on computing CFCs’ minimum taxes in BEPS Pillar Two – Treasury Secretary says no delay in final foreign tax credit regulations – 28 CFOs comment on final foreign tax credit rules.

A review of the week's major US international tax-related news. In this edition: Congress returns from Memorial Day holiday to budget reconciliation uncertainty – Support Ukraine Through Our Tax Code Act introduced in the House – US government supports excluding reinsurance and asset management from the BEPS 2.0 Pillar One – OECD initiates public consultation on BEPS Pillar One tax certainty – OECD Secretary General predicts BEPS 2.0 practical implementation from 2024 onwards.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats move “soft deadline” for BBB action to August recess – US Treasury offers insights to future FTC guidance – OECD officials discuss BEPS 2.0 progress.

A review of the week's major US international tax-related news. In this edition: US House leaders hope to pass “China competitiveness” bill before 4 July recess – Senate introduces bill to disallow foreign tax credits (FTCs) for taxes paid to Russia or Belarus – Treasury, IRS considering changes to FTC regulations – IRS proposed Section 1256 regulations on FX contracts set for release in coming weeks, Section 987 rules to follow – IRS issues GLAM on allocation and apportionment of deferred compensation expense for FDII deductions, reverses prior guidance – Treasury, OECD officials offer BEPS 2.0 insights.

A review of the week's major US international tax-related news. In this edition: Little action on budget reconciliation as US Congress focuses on ‘China competitiveness’ legislation – Treasury official reveals government working on “Killer B” cross-border triangular reorg regs, Section 367(d) rules involving transferred IP repatriated to US.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary calls on Congress to pass BEPS-like minimum corporate tax – Treasury officials comment on BEPS 2.0 – IRS publishes changes to QI withholding agreement rules – IRS unclear on scope of financial transaction transfer pricing regulation project – US House Ways and Means Committee members request delay to implementation of final FTC regulations – First-ever US-Croatia income tax treaty under US State Department review.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington to budget reconciliation uncertainty; Senator Manchin offers high-level clarity – OECD holds public consultation on Implementation Framework for BEPS 2.0 Pillar Two GloBE Rules – OECD releases public comments on Draft Model Rules for Domestic Legislation on Scope under Pillar One.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington; Democrats may make one last attempt at reconciliation legislation – Biden Administration supports both BEAT repeal and replacement with UTPR and BBB’s BEAT reforms.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary says BEPS 2.0 will help global economies recover from COVID-19 pandemic, Ukraine crisis – IRS releases new Schedules K-2, K-3 FAQs – US Senate Foreign Relations Committee issues report on proposed US-Chile tax treaty.

A review of the week's major US international tax-related news. In this edition: Prospects for post-Build Back Better Act reconciliation bill uncertain – Senate bill would deny US FTCs for Russian taxes paid – OECD announces public consultation on draft model rules on scope of Amount A in BEPS 2.0 Pillar One.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY2023 budget with international tax proposals – US Senate Foreign Relations Committee approves US-Chile income tax treaty – OECD public consultation on crypto-asset reporting framework expected by end of May.

A review of the week's major US international tax-related news. In this edition: President Biden to release FY 2023 budget on 28 March – Sen. Manchin revives pared-down budget reconciliation talks – Final US FTC regulations will be amended to reflect BEPS 2.0 Pillar One and Pillar Two – Senate Foreign Relations Committee to take up US-Chile tax treaty, US-Croatia treaty talks in final stages – OECD initiates public consultation on crypto-asset reporting framework, amendments to CRS.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – OECD releases BEPS 2.0 Pillar Two commentary – US Senate Finance Committee Chairman supports tax sanctions for Russia and Belarus – IRS official recommends all taxpayers seeking PLRs should avail of new fast-track process.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – Treasury official confirms previously-taxed earnings and profits regulations coming in latter half of 2022 – IRS official says partial US FTC may only be available on foreign withholding on IP royalties in certain instances.