Podcasts about beps action

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 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.

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'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.

Guest: GLIMSTEDT attorney-at-law & certified tax consultant, Gita Avotina Host: AGroup PR & Marketing Manager, Julia Kuznecova On 11 November 2021, the European Parliament gave the final approval on the EU Directive on public Country-by-Country Reporting (CbCR), formally known as the Directive of the European Parliament and the Council amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches. Glimstedt is a well-recognized & leading law firm, which provides AGroup and respectively all HRB Portal users with all the necessary suite of legal and regulatory support in Latvia, Lithuania, and Estonia, ensuring full compliance with local legislation and proper conditions to make informed & confident decisions that work. In this episode Gita Avotina, Glimstedt attorney-at-law & certified tax consultant answering the questions assumed that publishing CbCR on a voluntary basis might demonstrate the long-standing commitment to transparency since the positive impact outweighs the negative effect of higher tax payments. Furthermore, there are companies which have independently moved towards voluntary publishing, for example, Vodafone, BHP Billiton, Unilever. Besides, enhanced transparency could be considered as a pivotal goal. Also, it's worth noting that the EU Directive doesn't overlap other CbCR standards, such as BEPS Action 13 and Global Reporting Initiative-207 (GRI-207). Along with that, Gita has outlined that the most vital is the condition that information is public (disclosure of information) and is not filed only to the tax authorities. What's more the exchange of information has already been performed, but only for tax authorities. Which means that the companies by substance have been prepared since 2016. Additionally, non-EU companies are covered by the regulations as well, if non-EU parented companies if they are operating in the EU through medium-sized or large subsidiaries or branches.” HRB Portal podcast is brought by AGroup, a leading HR & business software provider in Baltics & Eastern Europe. To learn more visit us on agroup.lv --- Send in a voice message: https://anchor.fm/hrb-portal-podcast/message

Which countries are updating transfer pricing legislation? What do certain tax authorities want to see in local files? And are those country-by-country reports complying with BEPS Action 13's minimum standards? We've got the goods right here, hot off the press. CrossBorder Solutions · The Fiona Show - Facebook Page

Which countries are updating transfer pricing legislation? What do certain tax authorities want to see in local files? And are those country-by-country reports complying with BEPS Action 13's minimum standards? We've got the goods right here, hot off the press.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan Senate negotiators reach agreement on $1.2 trillion infrastructure package; Senate Democrats have votes to move on budget resolution – US, UK competent authorities sign agreements re: NAFTA and derivative benefits in treaty LOB – Treasury official offers international tax regulatory update – OECD releases sixth batch of peer reports on BEPS Action 14 minimum standard on dispute resolution.

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.

A review of the week's major US international tax-related news. In this edition: US Congress may address international tax regime in 2021, Senate aide says – US, Argentina sign agreement to share CbC reports – OECD holds public consultation on BEPS Action 14 dispute resolution –  Final draft of ‘Platform for Collaboration on Tax’ to be released in Q1 2021.

HMRC is opening criminal investigations into companies suspected of profit-diversion, Ghana joins the BEPS Action 13 club, and interest-free foreign subsidiary loans are now a red flag for an audit in Australia. CrossBorder Solutions · The Fiona Show - Facebook Page

HMRC is opening criminal investigations into companies suspected of profit-diversion, Ghana joins the BEPS Action 13 club, and interest-free foreign subsidiary loans are now a red flag for an audit in Australia.

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.

A review of the week's major US international tax-related news. In this edition: IRS to release revenue procedure on interaction of GILTI and CFC change of accounting method – US, Mexico renew CA agreement on unilateral APAs for maquiladoras – New IRS guidance on stock-based compensation re cost sharing arrangements coming – PLRs possible on tax treatment of virtual currency transactions – OECD issues consultation document on BEPS Action 14, Making Dispute Resolution More Effective.

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.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final and newly proposed foreign tax credit regulations – US Treasury issues final sourcing regulations on sales of personal property (including inventory) – OECD releases outcomes of third phase of peer reviews on BEPS Action 13.

In this episode, host Bianca Kuijper and guest Kim Majure unpack the OECD’s recently released set of mandatory reporting of cross-border arrangements requirements and what taxpayers and intermediaries can do to get ahead. Episode Notes: With complex tax codes and changing regulations, it’s no surprise that keeping up with tax reforms and complying with constantly changing regulations came up as the #1 challenge cited by our respondents in our newly published report.  Join our host, Bianca Kuijper, Director of Direct Tax and Trends for Pricing Propositions at Thomson Reuters as she discusses the many nuances of BEPS Action 12 with expert Kim Majure,  Principal at the International Tax group of KPMG's Washington National Tax practice. Questions? Contact us. Additional Resources: DAC6 compliance, now and for the long term, Change is the Only Constant in Tax– Keep Up by Embracing Technology Today, Bianca Kuijper’s LinkedIn Page, Kim Majure KPMG bio page  

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US CARES Act stimulus package to address COVID-19 has international tax implications – IRS expands 15 April tax relief and issues FAQs on extension of filing and payment deadlines, FATCA reporting – IRS issues final Section 901(m) regulations – TIGTA finds major FIRPTA withholding discrepancies – Alignment of transfer pricing regulations to TCJA provisions in relation to IP definition not expected before 2021 – OECD plans to continue BEPS 2.0 project virtually – OECD releases second annual peer review report on BEPS Action 6, prevention of treaty abuse – OECD releases CbCR comments.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary confirms DST deal with France – All major TCJA guidance expected by October 2020 – Pending US tax treaties with Chile, Hungary and Poland may require renegotiation over BEAT – IRS officials elaborate on limited Section 965 transition relief, BEAT PLR option – Altera files for certiorari in US Supreme Court in cost sharing case – OECD on track to complete BEPS 2.0 core principles in 2020 -- OECD offers tax revenue estimates for BEPS 2.0 proposals – OECD issues CbCR consultation document – OECD issues transfer pricing guidance for financial transactions – OECD offers draft model rules on platform operators for ‘sharing’ and ‘gig’ economy – OECD releases eight batch of peer review reports on BEPS Action 14.

In this edition: US releases USTR findings re France’s DST – US issues final and proposed BEAT regulations – IRS issues final and proposed FTC regulations – IRS issues final W/H and reporting regulations – IRS issues final Section 871(m) regulations on dividend equivalent payments, extends transition relief – IRS issues proposed regs on sourcing income from sales of certain personal property – IRS again  delays certain Section 987 FX regulations – Treasury grants another FBAR extension – Officials discuss OECD BEPS 2.0 Project – OECD hosts Pillar 2 GloBE public consultation – OECD releases additional CbC guidance – OECD releases BEPS Action 14 peer review reports.

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 One ‘unified approach’ – Treasury issues final regulations removing Section 385 documentation requirements, notice of proposed rulemaking for treating some interests as debt – IRS announces taxpayers can still rely on expired temporary Section 385 recharacterization rules – IRS issues proposed regulations and Rev. Proc. 2019-40 on repeal of Section 958(b)(4) – IRS proposed rules address tax consequences of elimination of LIBOR, other interbank offered rates – New US cryptocurrency tax guidance addresses some open questions, leaves others unanswered -- IRS CCA concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete – OECD releases sixth 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 announces entry-into-force for protocols with Japan, Spain, Luxembourg, and Switzerland – IRS issues proposed Section 382(h) regulations on built-in gains and losses – International TJCA guidance expected in fall – IRS reconsidering Form 1120-F nonfiler compliance campaign – OECD releases second phase BEPS Action 13 peer review – OECD holds first Tax Certainty Day, releases 2018 MAP statistics.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues proposed rules on cloud-based, other digital transactions – French President Macron comments on new Digital Services Tax – IRS increase cryptocurrency enforcement efforts – IRS will allow domestic partnerships, S corps to apply proposed GILTI regulations before 22 June 2019 – US Circuit Court of Appeals affirms Tax Court’s decision in Amazon case – IRS withdraws “Altera Memo” Directive on cost-sharing arrangement stock-based compensation – OECD releases US Stage 2 peer review on BEPS Action 14 minimum standard.

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on cloud-based, digital transactions – Revised version of IRS Publication 5188 on reporting FATCA data released – OECD issues BEPS Action 14 Stage 2 peer review reports on dispute resolution; includes US.

US Treasury official comments on OECD international tax deliberations – US supports global efforts to adopt corporate minimum tax – US government may miss June 2019 deadline to finalize TCJA international regulations – Final Section 965 regulations clarify filing Form 965-A or 965-B with transfer agreements – IRS LB&I requiring transfer pricing teams to consult with APMA – OECD opens public consultation on tax challenges from digitalization of the global economy – OECD releases fifth batch of peer reviews on BEPS Action 14 – OECD releases first annual peer review on BEPS Action 6

A review of the week's major US international tax-related news. In this edition: Efforts to update and align transfer pricing regulations and align them with TCJA now underway ─ NYSBA comments on Section 59A proposed Treasury regulations ─ General Court of the European Union annuls Commission's decision on Belgian excess profit rulings ─ OECD releases fifth batch of peer review reports on BEPS Action 14

US Congress fails to enact year-end tax legislation – JCT issues ‘Blue Book’ on 2017 Tax Cuts and Jobs Act – IRS issues proposed regulations on Section 59A BEAT – IRS issues proposed regulations on foreign persons’ taxable gain on sale of partnership interestes engaged in US business -- IRS issues proposed hybrid dividends / entities regulations – IRS announces future foreign corporate PTEP regulations – IRS issues proposed FATCA regulations – Treasury grants another FBAR extension – Puerto Rico enacts tax reform -- OECD publishes tax report to G20 leaders – OECD releases second annual peer report on BEPS Action 5

Congress returns for lame-duck session; year-end tax bill taking shape – IRS releases proposed regulations and related guidance on interest expense limitation under Section 163(j) – IRS issues proposed foreign tax credit regulations – IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j) – Taxpayers told to expect more ‘informal’ guidance, including on cryptocurrencies – IRS adds four new LB&I international compliance campaigns – US, Japan sign CbCR information exchange arrangement – Netherlands to repeal decree re: US-Netherlands tax treaty regarding hybrid entities – OECD issues guidance on MLI synthesized texts, MLI entry into effect – OECD updates results on preferential tax regimes, substantial activity requirements for no/nominal tax jurisdictions – OECD begins new BEPS Action 14 minimum standard review of additional jurisdictions

A review of the week's major US international tax-related news. In this edition: US, Singapore signed TIEA and new FATCA Model I IGA – OECD released update to 2017 Progress report on Preferential Tax Regimes – OECD Inclusive Framework on BEPS released substantial activities requirement for “no or only nominal tax” jurisdictions -- OECD now gathering input on implementation of BEPS Action 14 minimum standard for review of seventh batch of jurisdictions

A review of the week's major US international tax-related news. In this edition: OECD released fourth round of BEPS Action 14 peer reports on improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: White House official confirms ‘phase 2’ tax reform discussions with Congressional tax writers – US, Croatia considering tax treaty – OECD issues first peer report on BEPS Action 13 -- EU Council adopts Directive on new mandatory reporting of cross-border reportable arrangements.

In this episode we discuss BEPS Action 13 with Luis Carrillo, our global head of tax and transfer pricing solutions. Luis has over 16 years of transfer pricing advisory experience. Topics include: how Action 13 is changing the discipline of transfer pricing the effect BEPS is having on risk areas across a business what a company can do to navigate this new environment Bureau van Dijk captures and treats private company information for better decision making and increased efficiency. 

A review of the week's major US international tax-related news. In this edition: US government issues more repatriation transition guidance in Rev. Proc. 2018-17 – Treasury officials offer insights on future international TCJA guidance – US to defend TCJA’s FDII provision as WTO-compliant – IRS taking leadership role in OECD’s International Compliance Assurance Program -- OECD released more BEPS Action 13 CbC reporting guidance

US enacts comprehensive tax reform; revamps international tax rules -- Tax accounting among top issues following enactment of US tax reform -- EU officials reviewing US international tax reform measures -- IRS issues guidance on transition tax on foreign earnings -- IRS proposed regulations may alleviate foreign currency tax asymmetries for CFCs, provide new mark-to-market election for certain FX transactions -- IRS suspends withholding obligations under TCJA’s new Section 1446(f) -- IRS issues proposed regulations on international rules under BBA partnership audit regime -- OECD releases second batch of peer review report on BEPS Action 14 -- OECD releases first annual peer review report on BEPS Action 5 -- OECD invites taxpayer input on fourth batch of peer reviews of BEPS Action 14

US Congress gains momentum on tax reform; House W&M releases reform bill – Treasury outlines future actions on international regulations under Executive Order review -- Treasury to delay application of final Section 987 regulations by one year -- Treasury / IRS 2017-2018 Priority Guidance Plan shifts focus to reducing burdens and complexity -- OECD publishes two handbooks on CbCR - OECD releases progress report on preferential regimes under BEPS Action 5

Republican tax reform framework released; action moves to Congressional tax-writing committees – IRS offers relief for financial institutions required to obtain and report TINs – IRS issues proposed regulations on registration-required obligations and registered form rules – IRS issues updated draft APA template – OECD releases further CbCR guidance – OECD releases US peer review report on BEPS Action 14 minimum standards

Trump Administration to deliver detailed tax reform plan to Congress following August recess -- IRS signing competent authority agreements for CbCR exchanges -- IRS reviewing options for FTINs -- IRS LB&I reviewing how transfer pricing cases selected -- 68 jurisdictions sign Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS -- OECD seeks taxpayer input on BEPS Action 14 peer reviews -- OECD releases revised discussion drafts on profits splits, attribution of profits to permanent establishments.

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Trump Administration, Congressional Republicans look for unified tax reform proposal – Trump Administration’s FY2018 Budget offers few specifics on tax reform -- Trump Administration issues NAFTA renegotiation notice letters -- Changes made to IRS reporting under Sections 332, 351, 368 and 6038B by final regulations issued in 2016 affect filings for 2016 -- Treasury negotiating competent authority agreements to exchange CbC reports – US tax treaty negotiation update -- G7 Finance Ministers and Central Bank Governors communiqué references global tax system -- OECD releases implementation guidance on hard-to-value intangibles -- OECD releases peer review document on BEPS Action 6, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.

President Trump delivers address to Congress; US tax reform remains priority – LB&I announces first international tax campaigns in new issued-based exams and compliance process – US officials offer insights on Section 901(m), Section 385 guidance – Japan’s NTA confirms tax treatment of US LPs as fiscally transparent – IRS official confirms no major guidance in near term -- OECD begins peer reviews of BEPS Action 14 Dispute Resolution – OECD release peer review documents on BEPS Action 5 (Harmful Competition) and BEPS Action 13 (CbC Reporting) – OECD, UN, IMF, World Bank jointly release draft transfer pricing toolkit for developing countries.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Republicans finalizing open issues in Tax Reform Blueprint – OECD releases BEPS Action 6 Discussion Draft on treaty entitlement of non-CIV funds.

A review of the week's major US international tax-related news. In this edition: President-elect Donald Trump names Steven Mnuchin as next Treasury Secretary -- House Ways and Means Committee Chairman offers details on development of a tax reform package – US, India reach agreement on first bilateral APA – OECD releases text of multilateral instrument under BEPS Action 15.

US Treasury and IRS issue final and temporary Section 385 debt/equity regulations – What taxpayers should do now that final Section 385 regulations are released – IRS officials say cross-border intangible guidance, Section 871(m) package coming soon – US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation – US to exchange summaries of unilateral APAs in accordance with BEPS Action 5 – OECD holds consultation on BEPS profit attribution to PEs, revised guidance on profit splits – OECD released BEPS Action 14, "More Effective Dispute Resolution Mechanisms," peer review documents.

A review of the week's major US international tax-related news. In this edition: Congress adjourns until after November election; lame duck session expected – US, Argentina to begin tax treaty negotiations – IRS: Inbound asset reorganization in which US Parent acquired substantially all transferred corp’s assets terminated GRA -- OECD final report on BEPS Action 14, Make Dispute Resolutions Mechanisms More Effective, to be released soon – OECD announces agreement in principle on Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: Congressional Republican tax writers reiterate concerns over proposed Section 385 debt/equity regulations – US Treasury releases White Paper on European Commission's State aid investigations -- Ireland announces tax treaty talks with United States -- OECD releases discussion draft on branch mismatch structures under BEPS Action 2.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee reviewing base erosion issues in crafting international tax reform draft – US tax reform window in 2017 – IRS final outbound asset reorganization regulations released – OECD issued consultation document under BEPS Action 6.

US international tax reform, repatriation considered to pay for Highway Trust Fund -- Congressional tax leaders express BEPS project concerns -- Bill introduced to close PFIC ‘loophole’ -- IRS issues final Section 7874 regulations; retains bright-line rule of SBAT -- IRS reiterates that principles of Notice 2012-39 retroactively apply to outbound F reorgs with CFC shareholder -- OECD releases discussion draft on hard-to-value intangibles under BEPS Action 8 -- OECD issues implementation package for CbC reporting under BEPS Action 13 – Seven more countries agree to Common Reporting Standard.

A review of the week's major US international tax-related news. In this edition: IRS issues final anti-corporate inversion regulations – OECD issues discussion draft on BEPS Action 8 on hard-to-value intangibles -- Seven countries join OECD agreement to exchange financial information automatically.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups receive deadline extension -- DC Appeals Court rules 1% federal excise tax on reinsurance premiums inapplicable to retrocession agreements between foreign entities -- IRS reiterates US corporation in outbound F reorganization prior to effective date of Notice 2012-39 must recognize gain on IP -- OECD releases revised discussion draft on BEPS Action 6 on prevention of treaty abuse.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee international tax reform legislative text expected this summer -- US District Court in Lehman Brothers disallows FTCs in back-to-back stock loan transaction – ABA Tax Section meeting highlights coming US international tax guidance – OECD Update: public consultation held on BEPS Action 12 on mandatory disclosure rules, OECD’s Pascal Saint-Amans takes aim at multinational tech companies.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee ranking member releases report on tax avoidance through financial products, deferred compensation – US to release updates to 2006 model tax treaty in draft form – OECD consensus building on BEPS Action 4 on interest deductions.

Obama Administration’s FY 2016 Budget proposes major overhaul of US international tax system – IRS finalizes regulations under Section 909 foreign tax credit splitting events – IRS Chief Counsel memo addresses application of tax rate disparity test for foreign sales branches – IRS concludes US shareholder must increase E&P in year of Section 951(a)(1) inclusion – IRS releases competent authority agreement with Kazakhstan on treaty benefits for fiscally transparent entities – OECD addresses BEPS Actions 5, 13, and 15 – OECD holds public consultation on BEPS Action 4 on interest deductions and other financial payments.

US midterm elections change tax landscape; extenders activity dominates tax agenda in lame duck -- IRS issues regulations on deficient GRAs; withdraws Directive for remedying incomplete GRAs -- IRS releases limited supplemental guidance on codified economic substance doctrine -- IRS rules back-to-back loans structured to avoid Section 956 -- OECD releases discussion draft on low value-adding intra-group services, public discussion draft on follow-up work on treaty abuse under BEPS Action 6.

A review of the week's major US international tax-related news. In this edition: Congressional negotiators reach tentative tax extenders deal; President Obama threatens veto -- OECD releases public discussion draft on follow-up work on treaty abuse under BEPS Action 6.