Ernst & Young ITTS Washington Dispatch Ernst & Young

A monthly review of US international tax-related developments. In this edition:
US tax policy battle lines being drawn; House Republican tax writers form 10 TCJA ‘tax teams’ – US progress on global minimum tax will positively affect ongoing R&D talks, JCT updating BEPS Pillar Two analysis – IRS releases proposed rules on stock repurchase excise tax – IRS waives penalty for CAMT estimated tax – IRS final regulations on FIRPTA controlled QIE rules released – IRS releases draft Form 1099-DA on digital asset proceeds – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – IRS releases APA report for 2023 – OECD BEPS 2.0 status update – OECD releases consolidated GloBE commentary document, revised GloBE examples.

A monthly review of US international tax-related developments. In this edition:
President Biden delivers State of the Union; releases FY2025 Budget with international tax proposals – Congress passes final FY2024 funding bills, tax bill in limbo – Treasury Secretary defends Administration’s BEPS position at Senate hearing – House Ways & Means Subpanel holds OECD BEPS Pillar One hearing – IRS delays Form 1042 electronic filing requirement for US and foreign W/H agents – US officials offer international regulatory update – IRS will no longer issue single-issue PLRs, instead focus on ‘transactional rulings’ – IRS official discusses benefits of MAP mandatory arbitration – OECD releases update on BEPS 2.0 project – OECD Council approves update to Model commentary on exchange of information.

A monthly review of US international tax-related developments. In this edition:
OECD releases final guidance on BEPS Pillar One Amount B on baseline distribution – Finalization of proposed FX regulations expected by year end, two sets of proposed Section 367 regs in first half of 2024 – US Senate approves IRS Chief Counsel nomination – IRS sending more letters regarding transfer pricing compliance – OECD releases 2024 update on peer reviews under BEPS Action 5 on harmful tax practices.

A monthly review of US international tax-related developments. In this edition:
US House passes tax package, Senate action uncertain – Congress approves CR to fund government until early March 2024 – IRS signals new Section 367(d) guidance in 2024 on repatriation of IP – US officials provide regulatory update – IRS announces cryptocurrency transactions do not need to be reported until regulations issued – User fee for APAs increase, effective 2 February 2024 – US official offers BEPS Pillar One insights – OECD releases updated estimates of the economic impact of BEPS Pillar Two.
 
 

A monthly review of US international tax-related developments. In this edition:
IRS interim CAMT guidance provides relief from possible double-counting of CFC earnings in AFSI – IRS hasj CAMT compliance initiative – Treasury provides guidance on creditability of BEPS Pillar Two taxes, relief for pre-GloBE DCLs and extends temporary FTC reg relief – IRS Interim guidance released on treatment of basis adjustments under Section 961(c) on inbound liquidations or asset reorganizations – US officials offer international regulatory update – US Treasury announces entry into force of US-Chile tax treaty – IRS updates list of US treaties – US Supreme Court hears oral arguments in Moore transition tax case – FASB modifies income tax disclosure rules – US HQ’ed FG500 companies increase, reversing downward trend – OECD/G20 IF releases BEPS Pillar Two GloBE rules guidance, new Pillar One MLC timeline.

A monthly review of US international tax-related developments. In this edition:
US Congress approves new CR, complicates options for year-end tax bill – House Ways and Means Committee clears US-Taiwan tax bill – Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership WHT – US court denies DRD after applying economic substance doctrine – IRS issues proposed regs on QBUs, including simplified elections for determining Section 987 gain or loss but restrictions on loss recognition – OECD, country officials discuss BEPS 2.0 Pillars One and Two.