EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition:  US Congress to move on budget reconciliation after recess – IRS withdraws regulations on certain partnership related-party basis-shifting transactions – OECD/G20 IF on BEPS issues statement following meeting, OECD official comments on discussions – UN negotiating committee of Framework Convention on International Tax Cooperation releases roadmap and guidelines – US launches investigation into pharmaceuticals and semiconductors.

A review of the week's major US international tax-related news. In this edition:  Congress to begin budget reconciliation drafting following two-week recess – US pauses additional country-specific tariff rates, increases tariffs on China – President Trump signs repeal of crypto-reporting final regulations – IRS requests submissions for 2025-2026 Priority Guidance Plan.

A review of the week's major US international tax-related news. In this edition:  US Senate releases FY2025 budget resolution; vote pending – President Trump announces far-reaching trade agenda, including 10% universal tariffs and country-specific ad valorem tariffs.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans moving forward on budget reconciliation – President Trump announces 25% additional import tariffs on automobiles and automobile parts – House Ways and Means Republicans reintroduce “Unfair Tax Prevention Act” in response to Pillar Two – IRS releases 26th annual APA report – US, Swiss competent authorities agree to extend treaty benefits to certain pension, retirement arrangements.

A review of the week's major US international tax-related news. In this edition:  President Trump to receive recommendations for US response to BEPS Pillar One and Two – Congress will resume budget reconciliation work following recess.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans coalescing around single budget reconciliation bill – Congress poised to pass CR to fund the government – Congress votes to repeal IRS final regs on ‘DeFI' digital asset reporting – Trump Administration selects Washington Council Ernst & Young's Rebecca Burch to be Treasury Deputy Assistant Secretary for International Tax Affairs.

A review of the week's major US international tax-related news. In this edition:  President Trump calls for permanent tax cuts during joint session of Congress – Trump Administration imposes tariffs on Canada and Mexico, then reverses – US House Ways and Means Committee set to begin drafting budget reconciliation bill to extend expiring TJCA provisions – US Congress to address expiration of government funding on 14 March – Senate votes to repeal Biden-era regulation requiring some cryptocurrency reporting.

A review of the week's major US international tax-related news. In this edition:  US House passes FY'25 budget resolution, provides framework for reconciliation bill – White House memo sets stage for DST action – Trump administration to review US-PRC income tax treaty – IRS acting commissioner retires, replaced with COO – OECD releases consolidated report on Pillar One Amount B.

A review of the week's major US international tax-related news. In this edition:  President Trump endorses House Budget Committee's FY 2025 budget resolution – Trump Administration expected to release details on US DST action – White House issues EO on regulatory review process – President Trump comments on forthcoming auto and semiconductor chip tariffs.

A review of the week's major US international tax-related news. In this edition:  US House Budget Committee approves FY'25 Budget Resolution in first step to budget reconciliation legislation – President Trump signs country-by-country reciprocal trade and tariffs memorandum – OECD updates main documentation package for MNEs participating in ICAP risk assessments.

A review of the week's major US international tax-related news. In this edition:  President Trump meets with House Republicans to discuss tax bill framework – US tariffs on Canada and Mexico delayed – President Trump signs EO on regulations repeal – IRS GLAM clarifies government position on arm's length standard – US withdrawing from UN talks on international tax cooperation framework.

A review of the week's major US international tax-related news. In this edition:  US House leadership offers budget reconciliation timeline – Recent Trump Executive Order on OECD global tax deal may not necessarily affect IRS guidance on BEPS Pillar One Amount B – Hungary's PM authorizes US tax treaty negotiation.

A review of the week's major US international tax-related news. In this edition:  President Trump signs Executive Orders on BEPS project and trade policy – US House Ways & Means Committee Chairman introduces bill to punish countries imposing discriminatory taxes against US companies – President Trump addresses Davos Economic Forum on US taxation – IRS Commissioner resigns effective 20 January.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump to usher in new administration on 20 January – US House passes Taiwan tax bill – US officials address CAMT guidance – US, France issue statement on exchange of CbC reports for 2024 and 2025 – US officials comment on BEPS 2.0 project – OECD IF co-chairs provide status report on Pillar One Amount A and B – OECD compiling list of related-party transactions used to thwart Pillar Two global minimum tax – OECD releases three packages of BEPS Pillar Two 2.0 global minimum tax guidance.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump open to two budget reconciliation bills, prefers one – House W&M Committee leaders introduce Taiwan tax bill – IRS issues comprehensive package on classification, sourcing of digital content and cloud transactions – IRS releases final regulations on DPLs, extending BEPS Pillar 2 transition relief for DCLs – Final rules released on certain partnership related-party basis shifting transactions – IRS CCA addresses transaction reducing future GILTI inclusion.

A review of the week's major US international tax-related news. In this edition:  US House and Senate return to Washington, House retains Johnson as Speaker – Congressional Republicans lack unanimity on path forward for budget reconciliation – IRS releases technical corrections to CAMT regulations – IRS issues final consolidated return regulations – Cryptocurrency guidance released – IRS will apply economic substance doctrine to transfer pricing cases – UN General Assembly approves resolution on terms for UN Framework Convention on International Tax Cooperation.

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans continue to hold differing views on 2025 budget reconciliation – US to adopt OECD's Amount B simplified and streamlined approach to intercompany transactions beginning 2025 – US announces partial suspension of 1973 US-USSR tax treaty application to Belarus – US international tax officials leaving government – OECD BEPS project update – OECD releases pricing automation tool and fact sheets to implement BEPS Pillar One Amount B – OECD releases peer review report on Action 5 exchange of tax rulings.

A review of the week's major US international tax-related news. In this edition:  US Congressional Republicans consider plans for budget reconciliation bills in 2025 – Congress must pass government funding by 20 December, US-Taiwan tax bill still possible – IRS issues final and proposed FX regulations – US-Norway CAA released – IRS requests comments on APA and mutual agreement procedures.

A review of the week's major US international tax-related news. In this edition:  Congressional Republicans consider budget reconciliation options to enact legislative agenda – Congress to address government funding that expires on 20 December 2024 – President-elect Trump nominates new IRS Commissioner – IRS releases long-awaited PTEP proposed regulations – Cyprus clarifies exchange of CbC reports with US.

A review of the week's major US international tax-related news. In this edition:  President-elect Trump nominates Treasury Secretary, fills out economic team G20 Leaders' Declaration addresses international tax and BEPS 2.0 project OECD Global Forum on Transparency / Information Exchange announces 61 jurisdictions joining CARF

A review of the week's major US international tax-related news. In this edition: Congressional Republicans eye two budget reconciliation bills in 2025 to enact tax legislation – OECD holds Tax Certainty Day, releases 2023 MAP and APA statistics.

A review of the week's major US international tax-related news. In this edition: Republican US election sweep likely means TCJA extension via reconciliation, BEPS 2.0 project uncertainty – Final IRS Section 987 FX gain / loss regulations release before year-end – IRS comments on new passthrough field unit organization – IRS will permit digital asset transaction reporting on schema, not IRS Form 1042-S – IRS official says companies that ignored TP compliance letters referred for examination.

A review of the week's major US international tax-related news. In this edition: US 2024 election to have major impact on US tax policy – IRS to issue PTEP, Section 987 FX guidance by year-end – US to release notice on voluntary “Amount B”.

A review of the week's major US international tax-related news. In this edition: US announces tax agreement negotiations with Taiwan – IRS launches new LB&I pass-through field operations unit, EY's Jeff Erickson chosen to lead – IRS announces new FATCA relief for FFIs – US officials discuss coming changes to CAMT regs – IRS official recommends expanding OECD Treaty Article 25 MAP scope – OECD official offers BEPS IF update.

A review of the week's major US international tax-related news. In this edition: US House legislators urge Taiwan tax negotiation – IRS launches new LB&I passthrough field operations unit – IRS official discusses CAMT campaign – OECD releases tax report to G20 Finance Ministers and Central Bank Governors.

A review of the week's major US international tax-related news. In this edition:  Congress out of session until mid-November despite calls to reconvene and pass necessary funding measures – Upcoming election too close to predict for both presidential and congressional races – 2024 Annual Meetings of the IMF and World Bank Group to take place in Washington next week – IRS releases AM 2024-002 addressing application of Section 246(b) limitation to deductions under Sections 243, 245 and 250 – Italy and France propose changes to their digital services taxes, potentially increasing tax burdens on technology companies.

A review of the week's major US international tax-related news. In this edition:  IRS releases final IP repatriation regulations – Treasury and IRS will release technical corrections to CAMT regs – IRS final DCL regulations will clarify anti-avoidance rule – OECD issues working paper on tax arbitrage through closely held businesses.

A review of the week's major US international tax-related news. In this edition:  US general election will have major impact on tax policy IRS to update draft digital asset reporting instructions for Form 1099-DA OECD issues FAQs on CARF EY releases comprehensive analysis of proposed CAMT regs 

A review of this week's major US international tax-related news. In this edition:  US presidential candidates reveal tax positions – Congress averts government shutdown with continuing resolution, adjourns until after election – US officials discuss CAMT – Digital asset noncustodial broker reporting guidance coming before year end – Puerto Rico initiates public consultation on BEPS 2.0 GloBE rules – OECD holds signing ceremony for BEPS Pillar Two Subject to Tax Rule Multilateral Instrument.

A review of this week's major US international tax-related news. In this edition:  US House Speaker promises “Day One” focus on corporate tax policy with Republican election sweep – IRS soon to release final Section 367(d) regs on IP repatriation – IRS final Section 987 FX regs to reserve on partnership issues – IRS guidance on BEPS Pillar One Amount B coming before year end – IRS official clarifies ‘disregarded payment loss' rules effective date in recent DCL regs – IRS soon to release guidance on MAP and APA program – IRS assembling CAP transfer pricing team – OECD issues seventh annual BEPS Action 13 CbCR peer review report.

A review of this week's major US international tax-related news. In this edition:  US Treasury issues proposed regulations on CAMT, extends penalty relief for failure to pay estimated CAMT – Treasury and IRS officials to evaluate narrowing scope of future anti-partnership basis-shifting guidance – Official offers international regulatory update – OECD releases standardized ICAP template for tax administration outcome letters – OECD to address incentives that undermine BEPS Pillar Two GloBE rules.

A review of this week's major US international tax-related news. In this edition:  US Congress to return to Washington; consideration of tax packages to begin – IRS corrects proposed regs to permit foreign currency mark-to-market election to be made with returns filed after 19 August 2024 – USTR requests dispute settlement consultations with Canada under USMCA to address recent enactment of Canadian DST.

A review of this week's major US international tax-related news. In this edition:  US Tax Court rules taxpayer entitled to DRD, but limits foreign tax credit.

A review of this week's major US international tax-related news. In this edition:  IRS issues new proposed regulations that limit / modify taxpayers' FX elections – UN Committee advances Terms of Reference for convention on international tax cooperation.

A review of this week's major US international tax-related news. In this edition:  US economic and tax policy become focus in Presidential race – IRS issues early draft form for brokers to report digital assets sales and exchanges – IRS expanding Compliance Assurance Process program to privately held corporations, including foreign-owned – OECD releases transfer pricing framework for lithium.

A review of this week's major US international tax-related news. In this edition:  US Treasury and IRS issue proposed DCL regs addressing BEPS Pillar Two, other issues.

A review of this week's major US international tax-related news. In this edition:  US Congress adjourns for August recess – Senate fails to move Tax Relief for American Families and Workers Act with international provisions – G20 / Central Bank Governors communiqué reiterates support for BEPS 2.0 project 

A review of this week's major US international tax-related news. In this edition:  US House begins summer recess, Senate has additional week – DC Circuit Court of Appeals reverses Tax Court; FP's gain from inventory on US partnership disposition is foreign-source – IRS official comments on pending CAMT guidance – PTEP regulations in the ‘home stretch.'

A review of this week's major US international tax-related news. In this edition:  US IRS releases final Section 367(b) regs addressing cross-border triangular reorganizations, inbound nonrecognition transactions – Congress reacts to Supreme Court's Loper Bright decision invalidating Chevron – OECD Inclusive Framework close to finalizing MLC text on Pillar One Amount A, expanded Amount B framework.

A review of the week's major US international tax-related news. In this edition: IRS issues procedural final regulations on stock repurchase excise tax – IRS releases final digital asset broker reporting regs, transitional relief for certain brokers – Canada's DST in force, US legislators react – OECD releases draft BEPS 2.0 User Guide for GloBE information return XML Schema.

A review of the week's major US international tax-related news. In this edition: US Supreme Court ends court deference to agency interpretations of ambiguous laws, including tax laws – US House Republican Tax Team on global competitiveness to hold first field meeting with stakeholders on 8 August, White Paper to follow – IRS will address DCL income allocation rules in context of BEPS Pillar Two global minimum tax jurisdictional tax blending – US, Switzerland sign new FATCA Model 1 agreement – US Treasury and OECD officials offer insights on BEPS 2.0 Pillar One and Pillar Two project.

A review of the week's major US international tax-related news. In this edition: US Supreme Court upholds validity of IRC Section 965 mandatory repatriation tax – US Treasury Department suspends key provisions of US-Russia Tax Treaty and Protocol – IRS issues package on certain related-party partnership basis shifting transactions – OECD/G20 Inclusive Framework releases documents on BEPS Pillar One Amount B and Pillar Two.

A review of the week's major US international tax-related news. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – IRS again extends penalty relief for failure to pay estimated CAMT.

A review of the week's major US international tax-related news. In this edition: US IRS officials discuss pending CAMT, stock buy-back regs – BEPS Pillar One Amount B package to be finalized soon – OECD releases updated FAQs on ICAP program.

A review of the week's major US international tax-related news. In this edition: OECD will release two more rounds of BEPS Pillar Two GloBE administrative guidance – US will not sign Pillar One MLC until India and China agree to unresolved transfer pricing issues.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee launches new TCJA public comment portal – US opposes annual billionaire global wealth tax proposal – IRS notice extends Section 871(m) transition relief for dividend equivalent transactions – IRS to defer applicability date of some provisions in Sections 59A and 6038A regs for qualified derivative payments – Section 6045 final crypto reporting regulations coming in 2024 – OECD committed to open BEPS Pillar One multilateral convention for signature in June – Work continuing to finalize BEPS Pillar One Amount B provisions.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Chair working with Majority Leader to bring tax bill to Senate floor – CBO releases new revenue estimate on TCJA extension – White House National Economic Advisor offers insights into Biden Administration tax policy 

A review of the week's major US international tax-related news. In this edition: US Ways and Means Chairman says all current TCJA measures will be on the table in 2025 –  Treasury official says proposed regulations on CAMT in advanced stage.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing highlighted expiring TCJA, OECD BEPS – IRS updates rules for requesting PLRs on Section 355 transactions.

A review of the week's major US international tax-related news. In this edition: US tax policy lines being drawn ahead of 2024 election, TCJA ‘cliff' – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – OECD releases consolidated GloBE commentary document, revised GloBE examples.

A review of the week's major US international tax-related news. In this edition: IRS waives penalty for failure to pay estimated CAMT – OECD BEPS 2.0 update: what's coming – IESBA announces changes to its Tax Planning and Related Services project that will apply to all tax planning activities.