Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: President Biden presents first State of the Union address; lists provisions but does not mention Build Back Better – Sen. Manchin says he could support limited reconciliation package focused on taxes, climate change and deficit reduction – Senate Democrats eye US-Russia tax treaty in response to Ukraine crisis.

A review of the week's major US international tax-related news. In this edition: OECD officials reconfirm ambitious BEPS 2.0 timeline; provide further details – OECD is finalizing tax reporting framework for cryptoassets.

A review of the week's major US international tax-related news. In this edition: US Senate mulls anti-inflation measures – IRS releases FAQs on transition relief for certain domestic partnerships and S corporations completing new Schedules K-2 and K-3 – Treasury official comments on future proposed regulations on cryptocurrency reporting requirements for brokers – OECD official concedes BEPS 2.0 Pillar One draft rules complexity – Republican Senate Finance Committee members concerned over BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US inflation report may affect size and scope of future social spending, climate and tax bill – Increasing signs Congress may act on year-end 2021 tax changes.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin reiterates need for wholly new spending and tax bill; Congress faces full agenda – OECD announces first wave of consultations on the BEPS 2.0 Pillar One rules, releases consultation document – OECD official reinforces BEPS 2.0 timeline.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin confirms Build Back Better discussions back on – Concern over double taxation if US GILITI unamended – Republican tax writers warn BEPS Pillars require  congressional action – Treasury releases final regulations on treatment of domestic partnerships under Section 958, proposed PFIC regulations – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework.

A review of the week's major US international tax-related news. In this edition: President Biden favors breaking up Build Back Better into smaller bills – OECD BEPS 2.0 Pillar Two model rules commentary expected in early February – OECD releases 2022 Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: No action on President Biden’s Build Back Better agenda as Congress pivots to other legislative priorities – Treasury developing interim guidance on cryptocurrency reporting.

A review of the week's major US international tax-related news. In this edition: Build Back Better Act faces uncertain path – Treasury and IRS release final foreign tax credit regulations – IRS finalizes rules addressing the tax consequences of the elimination of LIBOR and other interbank offered rates.

A review of the week's major US international tax-related news. In this edition: Senator Joe Manchin will not support Build Back Better Act; Majority Leader will bring forward ‘modified’ version of bill in new year – OECD releases Model Rules on the Pillar Two Global Minimum Tax.

A review of the week's major US international tax-related news. In this edition: US Senate will not take up Build Back America Act in 2021 – Updated Senate Finance Committee's title of the Build Back Better Act retains House’s international tax proposals, but with major technical changes – Final foreign tax credit regulations clear OMB, return for final Treasury review – OMB reviewing final regulations on interbank offered rates (IBORS) – OECD to release Pillar Two Global Anti-Base Erosion Model Rules on 20 December.

A review of the week's major US international tax-related news. In this edition: US Senate Democratic BBBA meetings with Parliamentarian concluded; bipartisan “Byrd bath” meetings begin next week – Senate Foreign Relations Committee Republicans urge vote on proposed 2010 US-Chile tax treaty – Treasury’s FinCEN published proposed regulations on beneficial ownership.

A review of the week's major US international tax-related news. In this edition: US Congress turns to Build Back Better reconciliation bill after recess – Final foreign tax credit regulations release before year-end -- US, India announce digital tax, trade action compromise – Technical aspects of model rules for OECD BEPS Pillar 2 complete; further Pillars’ consultation planned.

A review of the week's major US international tax-related news. In this edition: US, Turkey announce digital tax, trade action compromise – OECD committed to BEPS Pillars in effect by end of 2023 – US Congress in recess; Senate expected to take up House-passed Build Back Better Act after Thanksgiving break.

A review of the week's major US international tax-related news. In this edition: President Biden signs infrastructure legislation – House passes Build Back Better Act budget reconciliation bill, Senate consideration after Thanksgiving holiday – IRS releases new tool to support US withholding agents compliance with reporting, withholding re IRS Form 1042-S – IRS requests comments on Rev. Proc. 2015-41 regarding APAs and MAP applications and compliance.

A review of the week's major US international tax-related news. In this edition: President Biden to sign infrastructure legislation next week with crypto provisions; House Speaker wants reconciliation vote week of 15 November – Final foreign tax credit regulations expected before year-end – Proposed PTEP regulations moving forward.

A review of the week's major US international tax-related news. In this edition: US House poised to pass Build Back Better Act budget reconciliation bill, infrastructure legislation – IRS ILM concludes extended six-year assessment period under Section 6501(e)(1)(c) applies to entire tax liability, not just omitted subpart F and/or GILTI items.

A review of the week's major US international tax-related news. In this edition: New $1.75 trillion US budget reconciliation framework and legislative text released; tax items not fully settled.

A review of the week's major US international tax-related news. In this edition: Negotiations continue in congress to reach agreement on House reconciliation bill – Treasury releases joint statement with several countries on DST Agreement – IRS issues commodity derivatives private letter ruling – Platform for Collaboration on Tax enhances support to countries in the area of domestic resource mobilization during the COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Debate continues over size and scope of US budget reconciliation bill – G-20 Finance Ministers endorse BEPS 2.0 Pillar One and Pillar Two agreement – US officials discuss implementation of BEPS 2.0 – US to defer by one additional year applicability date of final Section 987 FX regulations, certain related final regulations – Cyprus clarifies Cyprus-US CAA for exchange of CbC reports.