Ernst & Young ITS Washington Dispatch

A monthly review of US international tax-related developments. In this edition: US Congress begins August recess – US Supreme Court overrules Chevron deference to agency regulations – US appellate court rules NR's gain from sale of its US partnership interest attributable to inventory is not US source income – IRS final Section 367(b) regs address certain cross-border triangular reorgs, inbound nonrecognition transactions – IRS officials offer update on CAMT, PTEP guidance – IRS and Medtronic file Eighth Circuit appellate briefs arguing for different transfer pricing methods – IRS official says corporations failing to respond to TP compliance letters referred for possible examination – G20 Finance Ministers, Central Bank Governors reiterate support for BEPS 2.0 – Inclusive Framework on BEPS finalizing MLC to implement Pillar One Amount A, Amount B consensus near – OECD releases sixth edition of Corporate Tax Statistics publication, Draft User Guide for GloBE Info Return XML Schema.

A monthly review of US international tax-related developments. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – US Supreme Court upholds Section 965 mandatory repatriation tax – IRS finalizes regs on reporting / payment of stock repurchase excise tax – IRS releases final digital asset broker reporting regulations, transition relief for certain brokers – IRS addresses certain related-party partnership basis-transactions – IRS extends penalty relief for failure to pay estimated CAMT to installment due August 2024 – US officials comment on pending CAMT guidance – IRS clarifies changes to 2023 QI agreement in new FAQs – US suspends key provisions of US-Russia tax treaty and protocol – OECD/G20 IF releases documents on Pillar One Amount B and Pillar Two – OECD updates FAQs for MNEs participating in ICAP risk assessments.

A monthly review of US international tax-related developments. In this edition: US House Republicans prepare for TCJA ‘cliffs' – White House official previews President Biden's tax policy for second term – US House Ways and Means Chairman, Treasury Secretary spar over TCJA, BEPS 2.0 – US will not sign BEPS Pillar One MLC without India, China TP resolution – IRS extends transitional relief under Section 871(m) for treatment of dividend equivalents – IRS to defer applicability date re: Sections 59A and 6038A regs for qualified derivative payments – New procedures for Section 355 transaction PLRs released – CAMT regs in advanced stage – Final crypto reporting rules coming in 2024 – IRS proposed regulations on foreign trusts and large foreign gifts released – More OECD BEPS 2.0 GloBE guidance coming – BEPS Pillar One MLC on track for signature in June.

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.    

A monthly review of US international tax-related developments. In this edition: OECD releases text of Amount A Pillar One MLC, US Treasury announces consultation – OECD/G20 IF MLC to implement Pillar Two STTR – US House elects new Speaker – US-Taiwan legislation moves forward – IRS proposed regs would amend Section 367(b) rules re cross-border triangular reorgs, inbound nonrecognition – US officials offer update on pending international guidance –  IRS informing taxpayers of Schedule UTP non-compliance – IRS sending compliance alerts to US subs of foreign-owned corporations – IRS to broaden scope of corporate PLRs – US-Chile tax treaty's US reservations reflect current policy – IRS appeals Tax Court's latest decision in Medtronic – US, Israel sign CAA on CbC report exchange – Cyprus clarifies future CbC agreement with US.

A monthly review of US international tax-related developments. In this edition: US Senate Finance Committee approves US-Taiwan tax bill – House Republicans want countries to delay BEPS Pillar Two, adopt GILTI-like regime – Senate Finance Committee considers IRS Chief Counsel pick – IRS publishes additional interim guidance clarifying CAMT – IRS announces intent to issue proposed regulations for Section 174, would affect cost sharing arrangements – US Government considering extension of temporary FTC relief, guidance on taxes paid under BEPS Pillar Two – IRS official offers international regulatory update – IRS CAP program accepting new applications – IRS announces major new compliance initiative targeting large partnerships.

A monthly review of US international tax-related developments. In this edition: US Congress to take up appropriations bills, consider US-Taiwan tax relationship – IRS proposes updating consolidated returns regulations, discarding unnecessary guidance – IRS issues proposed regs on broker reporting requirements for digital asset sales and exchanges – Cryptocurrency stakers must include rewards in gross income upon gaining control – Russia suspends US-Russia, other tax treaties – Progress reported on BEPS Amount A, Pillar One, further work on Pillar Two safe harbors – Global minimum tax filing simplification possible, OECD official says – UN releases final report on international tax cooperation.

A monthly review of US international tax-related developments. In this edition: US Congressional Republicans criticize BEPS 2.0 project – US Senate moves on US-Taiwan tax relations – Congress pivots to crypto assets, requests comments on tax uncertainties – Treasury temporarily delays controversial foreign tax credit regulations – IRS makes permanent fast-track corporate PLR program – OECD/G20 Inclusive Framework releases technical documents on BEPS 2.0 Pillars One and Two – OECD issues outcome statement on BEPS Pillars One and Two progress – OECD Secretary-General Tax Report provides international tax update – OECD releases 2023 report on tax transparency in Latin America.

A monthly review of US international tax-related developments. In this edition: US House Ways and Means Republicans release tax package – Congressional JCT provides revenue estimates for BEPS 2.0 Pillar Two – IRS waives addition to tax for corporation's failure to make estimated tax payments of its CAMT – IRS plans further IP guidance – US Senate approves US-Chile tax treaty, brings treaty closer to entry into force – BEPS 2.0 Project enters critical stage –  OECD releases 2023 update on peer review of preferential tax regime.

A monthly review of US international tax-related developments. In this edition: US Congress passes debt ceiling bill, averts possible default – House Ways & Means Republicans introduce tax increase on foreign companies to influence BEPS 2.0 tax deal – IRS proposed regulations would turn off Section 367(d) following certain IP repatriations – IRS addresses taxation of digital currency – US officials comment on CAMT – US negotiating tax agreements with Israel, Switzerland and Norway – US Senate Foreign Relations Committee reports out proposed US-Chile tax treaty – US House members introduce resolution calling for legislation to prevent double taxation between US and Taiwan – BEPS Pillar One to follow revised implementation plan – G7 Finance Ministers welcome OECD progress report on tax cooperation, reiterate commitment to Pillars One and Two implementation.

A monthly review of US international tax-related developments. In this edition: US House Republicans pass debt ceiling, spending bill; impasse continues – IRS provides transition period for documentation requirements for FTC ‘single country exception' – IRS updates crypto notice, virtual currency remains unavailable to generate FX gain or loss – IRS addresses micro-captive transactions as listed transactions – IRS releases general plan for spending $80 million over next 10 years – IRS interim guidance on APA submissions fundamentally changes early stages of process – US Tax Court rules IRS cannot assess penalties under Section 6038(b) for willfully failing to report foreign income.

A monthly review of US international tax-related developments. In this edition: President Biden releases FY'24 Budget with major international policy proposals – US Treasury official says permanent safe harbor under BEPS Pillar Two GloBE rules unlikely – OECD holds public consultation meeting on BEPS 2.0 global minimum tax compliance and tax certainty – US officials offer insights on pending international tax regulatory projects – Turkish Lira's hyperinflationary status has US federal tax implications for MNEs – IRS announces guidance plans on certain NFTs as collectibles – IRS planning new APA process – IRS considering Section 482 regulation for parent's implicit support in pricing intercompany loans.

A monthly review of US international tax-related developments. In this edition: President Biden delivers State of the Union address, proposes fourfold increase in stock buyback excise tax, ‘billionaire surtax' – House Ways and Means Committee Chairman calls BEPS Undertaxed Profits Rule ‘fundamentally flawed' – Proposed PTEP regulations to be released in latter half of 2023 – IRS addresses deductions involving cryptocurrency in two CCA memoranda –  OECD releases additional administrative guidance on BEPS 2.0 Pillar Two – OECD's Pillar Two administrative guidance raises implications for US MNEs – OECD FTA releases manual on MAP, APAs.

A monthly review of US international tax-related developments. In this edition: Kevin McCarthy new US House Speaker, Rep. Smith chairs Ways and Means Committee – JCT to release ‘Blue Book' on tax legislation by end of June – IRS issues final regulations for qualified foreign pension funds – IRS releases proposed regs on domestically controlled QIE rules under Section 897, certain controlled commercial entity rules under Section 892 – IRS addresses deductions involving cryptocurrency in two CCA memos – IRS to continue participation in ICAP – IRS examiners must consult IRS counsel to apply economic substance doctrine in transfer pricing audits.

A monthly review of US international tax-related developments. In this edition: US, Croatia sign income tax treaty – IRS issues interim guidance on CAMT – IRS releases guidance on new stock buyback excise tax – IRS issues final revised QI agreement effective 2023 – IRS releases more guidance for brokers on transfers of PTP interests – IRS issues proposed rules on single-entity treatment of consolidated groups – FinCEN continues to extend certain FBAR signature authority reporting, releases proposed beneficial ownership regs – OECD releases public consultation document on Pillar One Amount A and DSTs – OECD releases consultation document on tax certainty for Pillar Two GloBE rules – OECD releases consultation document on Pillar Two GloBE Info Return – BEPS 2.0 document issued on safe harbors and penalty relief under Pillar Two GloBE rules – OECD releases public consultation document on Amount B of Pillar One on baseline marketing and distribution functions.

A monthly review of US international tax-related developments. In this edition: IRS proposed FTC regulations offer relief from cost recovery and source-based attribution rules, other key changes – IRS moving forward on cryptoasset issues – Section 367(d) regs coming early next year, IRS official says – No delay or transition period for final Section 1446(f) regs implementation date – Congressional Republicans urge Biden Administration to not terminate US-Hungary treaty – IRS will consider applying economic substance doctrine and related penalties more frequently in transfer pricing audits – US House Republicans seek retention of BEPS Pillar One documents and communications – OECD updates guidance on implementation of CbC Reporting.

A monthly review of US international tax-related developments. In this edition: Proposed US FTC regs release expected soon, PTEP regs in first half of 2023 – US Treasury official says proposed crypto regs before year end – IRS may be more selective on APAs given availability of ICAP in transfer pricing disputes – IRS to reconsider APA revenue procedure guidance – Treasury developing measures for future treaties to address new tax regimes, new US-Croatia treaty before year end – G20 Finance Ministers welcome progress on BEPS 2.0, call for swift implementation – OECD releases public consultation document on administration and tax certainty aspects of Amount A of Pillar One – OECD releases report on interaction of Tax Incentives and Pillar Two – OECD/G20 Inclusive Framework holds 14th plenary meeting, publishes 6th annual progress report.

A monthly review of US international tax-related developments. In this edition: US tax treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates – IRS PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year – Proposed IRS regulations coming on application of noncompulsory payment regs to certain amended Puerto Rico tax decrees – IRS Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation – Sixth Circuit rules in favor of Eaton Corporation in APA cancellation – OECD holds public consultation meeting on Progress Report on Amount A of BEPS Pillar One – OECD issues bilateral APA manual – OECD's Pascal Saint Amans announces plans to retire.

monthly review of US international tax-related developments. In this edition: President Biden signs Inflation Reduction Act with 15% corporate minimum tax – Inflation Reduction Act includes 1% stock buyback excise tax – Congress passes $280 billion Chips and Science Act – Applicability date for FX regs under Section 987 extended again – IRS announces delay in effective date of Section 871(m) regulations – IRS Notice 2022-36 penalty relief applies to certain international tax information returns – US Tax Court increases Medtronic royalty rate under unspecified TP method – Increased IRS funding from Inflation Reduction Act may increase transfer pricing scrutiny – OECD releases 2022 update on peer review of preferential tax regimes and no or only nominal tax jurisdictions.

monthly review of US international tax-related developments. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740b budget reconciliation bill with 15% corporate minimum tax – Congress passes CHIPS bill with investment tax credits and incentives – Treasury and IRS publish technical corrections to final foreign tax credit regulations – IRS proposed regulations would limit Section 1256 mark-to-market accounting for FX contracts to FX forward contracts – Treasury announces termination of tax treaty with Hungary – OECD releases Progress Report on Amount A of Pillar One of BEPS 2.0 project – G20 Finance Ministers reiterate commitment to BEPS 2.0 two-pillar implementation.

monthly review of US international tax-related developments. In this edition: Democrats fail to reach consensus on pared-down budget reconciliation package – Treasury Secretary testifies in support of anti-inflationary measures, BEPS 2.0 – US Supreme Court accepts FBAR filing case – IRS to defer reporting for certain derivative payments in forthcoming BEAT regulations – IRS to expand transfer pricing audit coverage – OECD officials offer update on BEPS 2.0 Pillars One and Two – OECD releases public consultation docs on tax certainty under Amount A for Pillar One.

monthly review of US international tax-related developments. In this edition: US budget reconciliation remains stalled, but some behind-the-scenes talks – Senators introduce Support Ukraine Through Our Tax Code Act -- More US FTC guidance coming – US officials offer international tax projects update – IRS GLAM addresses allocating/apportioning ‘deferred compensation expense' for FDII deductions – Changes to QI withholding agreement rules expand QI W/H and reporting responsibilities – OECD officials offer BEPS 2.0 update – OECD issues recommendations to strengthen tax administrations' cooperation re international rules, including BEPS 2.0 – OECD releases public consultation on Regulated Financial Services Exclusion under Amount A for Pillar One.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress returns amid speculation over limited budget reconciliation – Senate proposal would disallow FTCs, other US tax benefits connected with operations in Russia or Belarus – IRS issues annual APA report for 2021 – New Schedules K-2 and K-3 FAQs released – OECD holds public consultation on Implementation Framework for Pillar Two GloBE Rules – OECD releases public consultation document on draft rules re scope under Amount A for BEPS Pillar One – OECD releases public consultation document on Extractives Exclusion under Amount A for Pillar One – OECD releases peer review reports on dispute resolution – OECD releases fourth annual peer review report on BEPS Action 6 on prevention of treaty abuse.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration releases FY2023 Budget with new international tax proposals – Congress passes omnibus appropriations bill with no tax title – Senate Finance Committee Chairman supports tax sanctions for Russia, Belarus – Final FTC regulations will be revisited to address BEPS 2.0 Pillar Two rules – Proposed PTEP regulations coming second half of 2022 – Senate Foreign Relations Committee reports out proposed US-Chile tax treaty – OECD releases Commentary and illustrative examples on Pillar Two Model Rules.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Senate Democrats backburner Build Back Better, look to address inflation's impact – G20 confirms BEPS 2.0 ambitious timeline; Republican Senators voice concerns – IRS releases FAQs on Schedules K-2 and K-3 transition relief – Treasury official briefs Senators on future cryptocurrency reporting regs – OECD releases BEPS 2.0 Pillar One public consultation on draft nexus and revenue sourcing rules – OECD releases Pillar One public consultation on draft rules for tax base determinations – OECD finalizing crypto reporting framework.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration looks to scaled-back Build Back Better legislation – House Ways and Means Committee Republicans warn congressional consent needed for BEPS 2.0 Pillars –  Final regulations released on treatment of domestic partnerships under Section 958, proposed PFIC regulations – IRS amends instructions for 2021 partnership Schedules K-2 and K-3, relevant to private equity, private capital funds – IRS announces fast-track pilot program to resolve corporate LTR requests in 12 weeks – US officials comment on cryptocurrency efforts – BEPS 2.0 model rules commentary expected to be released soon – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework – OECD publishes 2022 Transfer Pricing Guidelines – OECD releases eighth batch of Stage 2 peer review reports on dispute resolution.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration's Build Back Better legislation stalls in Congress; Senate Finance Committee releases updated international tax provisions – Senate Foreign Relations Committee Republicans urge vote on 2010 US-Chile tax treaty – Treasury releases final foreign tax credit regulations – IRS issues final rules on tax consequences of transition from LIBOR and other interbank offered rates in certain financial contracts – OECD releases Model Rules on Pillar Two Global Minimum Tax – OECD releases 2020 peer review report on BEPS Action 5 on Exchange of Information of Tax Rulings.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US House passes Build Back Better Act budget reconciliation bill; action moves to Senate – President Biden signs infrastructure legislation including new cryptocurrency reporting – Final FTC regs expected by year-end, PTEP regs in 2022 – New IRS tool supports withholding agents' compliance with Form 1042-S – IRS requests comments on APA, MAP applications and compliance – US, Turkey announce joint statement on unilateral digital tax compromise – India, US agree on transitional approach for 2% Equalization Levy prior to implementation of Pillar One rule – OECD remains committed to BEPS Pillars in effect by end of 2023 – OECD releases 2020 MAP statistics and awards

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden releases pared down budget reconciliation framework – G20 leaders confirm commitment to global tax changes under BEPS 2.0 – Six country Joint Statement on transitional approach to existing unilateral DST measures released – IRS rules gains, losses from commodity hedges sourced by reference to underlying hedged inventory property – Final Section 987 foreign currency regulations, certain related final regulations deferred by one additional year – IRS maintaining policy on “telescoping” in APA and MAP cases – Cyprus clarifies US-Cyprus CAA for exchange of CbC reports – MLI Conference of the Parties issues two opinions re MAP implementation and arbitration rules – UN releases MAP and Tax Dispute Resolution Handbook

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition:  US Congress fails to pass infrastructure and budget reconciliation legislation -- House Ways & Means Committee reports out reconciliation bill with major international tax proposals -- Senate Finance Committee Chairman releases partnership tax proposals -- Final foreign tax credit regulations will include jurisdictional nexus requirement -- IRS allows taxpayer to reverse GILTI "gap period" transaction through late CTB election -- IRS articulates five-factor test in determining income inclusion of reimbursement payments -- IRS issues final regulations on treatment of QIP and provides guidance on foreign tax credits -- IRS seeing more billion-dollar MAP cases -- IRS lists jurisdictions with US information exchange agreements that allow reporting certain deposit interest -- G7 Finance Ministers make progress on BEPS 2.0 issues in lead-up to October 2021 meetings.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US infrastructure legislation, FY 2022 budget resolution move forward – Senate Finance Committee Chairman, members release international tax discussion draft – Finance Committee Chairman introduces bill to amend tax treatment of financial derivative transactions – Senate-passed infrastructure bill would impose information-reporting requirements on sales of cryptocurrency, other digital assets – IRS extends to 1 January 2023 date for W/H on certain transfers, distributions related to PTP interests – US, Germany agree on exchange of CbC reports – IRS financial services campaign will not target specific transactions – OECD releases 2021 peer review update of preferential tax regimes – OECD releases corporate tax statistics publication, including anonymized/aggregated CbC report stats.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: White House, Senate negotiators reach agreement on $1.2 trillion infrastructure package – OECD announces conceptual agreement in BEPS 2.0 project; endorsed by G20 Finance Ministers, Central Bank Governors – US, UK competent authorities sign agreements re treaty LOB provision – IRS memo addresses CSA and inclusion of stock-based compensation costs – US Treasury official provides international tax regulatory update.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Bipartisan infrastructure deal reached, but road to passage uncertain – House passes corporate disclosure package requiring CbC tax reporting for multinationals – Biden Administration's proposed 15% minimum tax could come with requirement to disclose book-tax differences – IRS announces plans to amend BEAT regarding qualified derivative payment reporting – G7 Finance Ministers express strong support for global tax changes under BEPS 2.0 – OECD publishes model rules for information exchange for digital platforms.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury ‘Green Book' offers new details on international tax proposals – Senate hearing discusses Biden Administration's international tax proposals – House bill would require SEC regulations on CbC financial information disclosure, including taxes – US proposes 15% global corporate minimum tax to BEPS 2.0 Steering Group – President Biden proposes increased IRS budget to improve tax compliance – IRS modifies guidance on accounting method changes for certain foreign corporations – IRS official comments on treaty derivative benefits post-Brexit – US Government releases early drafts of 2021 Schedules K-2 and K-3 for Forms 1065, 1120-S and 8865 – Parties to OECD MLI release interpretative guidance. .

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury releases President’s plan to overhaul corporate tax system – US Senators release proposed International Tax Framework – President Biden lays out $1.8 trillion American Families Plan proposal – Senate Finance Committee chairman reintroduces clean energy legislation – Treasury Secretary proffers BEPS 2.0 Pillar One proposal to Inclusive Framework – IRS issues proposed regs to coordinate WHT, gain deferral for certain foreign persons and partnerships investing in Qualified Opportunity Funds – IRS releases FAQs on ICAP program for US multinationals – PTEP guidance not expected until early fall – US, Japan reach agreement on tax treaty arbitration process – OECD releases consultation document with proposed changes to Commentaries to OECD Model Tax Convention on Article 9 (Associated Enterprises) – OECD publishes Arbitration Profiles for 30 countries under MLI – IMF and OECD release joint report on carbon pricing – UN tax committee approves new digital taxation article for UN model tax treaty – UN releases new Transfer Pricing Manual.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden lays out $2 trillion + infrastructure plan to be paid for with tax increases – Senate Finance Committee holds international tax hearing – Congressional Democrats introduce international tax legislation – President Biden signs $1.9 trillion American Rescue Plan Act of 2021 – US, Japan reach agreement on tax treaty arbitration process – IRS opens initiative on virtual currency – IRS APMA program director discusses taxpayers’ treatment of COVID-related costs – IRS APMA Program releases annual APA update – OECD official floats BEPS 2.0 Pillar Two simplification – OECD publishes jurisdictions currently participating in International Compliance Assurance Programme.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress poised to enact $1.9t COVID relief bill with repeal of worldwide interest expense allocation – Treasury to consider reviving expired transfer pricing aggregation regulations – IRS continues APA/MAP case closures despite COVID restrictions – OECD FTA releases new handbook for ICAP – OECD holds public consultation on review of BEPS Action 14 minimum standard on dispute resolution – OECD releases 10th batch of peer review reports on BEPS Action 14.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary says no new taxes for now, commits to OECD BEPS discussions – New final regulations address application of Section 163(j) limitation to CFCs and partnerships, reserve on certain provisions – IRS allows remote signing / submission of authorization Forms 2848 and 8821 – IRS official says guidance on worldwide interest expense allocation a top priority, proposed FTC regs in 2021 – USTR finds DSTs adopted by six nations discriminatory; suspends DST-related punitive tariff actions on French goods – OECD IF political leaders promote global consensus following OECD public consultation on Pillar One / Two Blueprints – OECD Secretariat issues updated guidance on tax treaties re impact of COVID-19 pandemic.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax treaties as TCJA guidance nears completion – Treasury’s FinCEN further extends certain FBAR signature authority reporting over foreign financial accounts – IRS will continue ICAP joint risk assessment initiative – US transfer pricing enforcement remains priority while TCJA provisions may negate adjustments – IRS APMA seeing more queries on transfer pricing consequences of coronavirus pandemic – BEPS 2.0 Pillar One and Two comment period closes; public consultation set for 14-15 January 2021 – OECD issues guidance on transfer pricing implications of COVID-19, hard-to-value intangibles – OECD releases fourth peer review report on BEPS Action 5 on Exchange of Information of Tax Rulings – OECD’s FTA hosts virtual meeting of tax administration leaders.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Major policy changes expected following US November election – Treasury and IRS finalize regulations to reduce double taxation caused by anti-abuse rules on GILTI gap period – IRS officials provide international regulatory update – US, Mexico renew competent authority agreement on unilateral APAs for maquiladoras – IRS updates list of jurisdictions for automatic exchange of CbC reports – IRS reviewing stock-based compensation in cost-sharing context – OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 in mid-January 2021 – OECD releases Consultation Document on 2020 review of BEPS Action 14 – OECD releases 2019 mutual agreement procedure statistics, 2019 mutual agreement procedure awards –  OECD releases report on taxing virtual currencies.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS ‘practice unit’ offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of ‘telescoping’ in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Final BEAT regulations adopt proposed BEAT guidance with some changes − New final and newly proposed foreign tax credit regulations released − Treasury issues final sourcing regulations on sales of personal property (including inventory) − IRS releases final and proposed regulations re repeal of Section 958(b)(4) − IRS issues final regs on characterization of foreign persons’ gain or loss from sale / exchange of interests in partnerships engaged in US trade or business − Final Section 163(j) regulations generally applicable tax years on / after 13 November 2020 − IRS delays certain Section 987 FX regulations for additional year − Notice 2020-69 provides rules on entity treatment election for certain S corporations re GILTI in AAA inclusions − Final BEPS 2.0 Pillar 1 and 2 blueprints to be published 12 October 2020 − OECD releases third phase of peer reviews on BEPS Action 13.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – Treasury and IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules during GILTI gap period – US, Swiss competent authorities reach agreement on treaty arbitration process – UN Tax Committee issues proposal for taxing digital services income.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII and GILTI deduction – IRS releases new draft partnership Schedules K-2 and K-3 for international tax reporting – US announces action against France’s DST – G20 Finance Ministers / Central Bank Governors reiterate commitment to BEPS 2.0 pillars – OECD releases new corporate tax data including CbCR statistics – OECD issues model rules for data reporting by platform operators for sellers in sharing / gig economy.  

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for ‘pause’ in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I official offers insights to TCJA compliance campaign – IRS seeks 2020-2021 Priority Guidance Plan recommendations – OECD releases toolkit on taxation of offshore indirect transfers of assets – OECD circulates COVID-19 transfer pricing survey to BIAC members.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress considers further action to address coronavirus pandemic – IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect – Treasury and IRS announce references to NAFTA in US tax treaties should be interpreted as references to USMCA – IRS offers limited relief for filing Forms 8858 or 8865 – IRS announces modifications for filing APA and MAP requests, addresses pending and executed APAs –  New refocusing on BEPS, OECD official says – OECD holds public consultation on 2020 review of CbCR – OECD hosts webcast offering update on tax work during COVID-19 crisis; July IF meeting delayed to October 2020.