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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 Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.
A recap of the Treasury Department and IRS’s Priority Guidance Plan for the 12 months from July 2020 through June 2021. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights and commentary on subjects that affect the profession and clients. Learn more in this podcast.
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.
Beth Shapiro Kaufman breaks down what wealth and tax advisors need to know about the IRS and Treasury’s release of the 2018 Priority Guidance Plan. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights, and commentary on subjects that affect the profession and clients. Learn more in this podcast.
US government moving forward with TCJA international guidance, two more transition notices expected -- IRS guidance under new Section 965 prevents certain foreign corporations from making accounting period changes -- New guidelines issued for delinquent Forms 1120-F and waiver requests -- Treasury may delay Section 987 branch currency regulations until 2020 -- IRS updates Priority Guidance Plan with some TCJA international provisions -- IRS assumes major role in OECD’s International Compliance Assurance Program -- IRS announces increase in user fees for unilateral and bilateral APAs -- OECD releases additional CbCR guidance, country approaches to CbC reporting
Updated US Treasury/IRS 2017 - 2018 Priority Guidance Plan issued with TCJA projects – Treasury to delay effective date of final Section 987 branch currency regulations to 2020 – US to begin tax treaty negotiations with Armenia
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
Congressional Republicans maintain opposition to Proposed Section 385 regulations -- IRS focusing on FATCA IGAs currently ‘in effect’ -- Obama Administration issues White Paper on EU State aid investigations – IRS final regulations issued on 2% tax on payments US government makes to foreign persons under certain contracts -- Treasury/IRS 2016-2017 Priority Guidance Plan contains several new international tax projects -- Lawsuit filed challenging anti-corporate inversion regulations -- OECD releases Discussion Draft on branch mismatch structures.
In this week's Tax Credit Tuesday Podcast, Michael J. Novogradac begins with the general news section, where he talks about the IRS 2016-2017 Priority Guidance Plan and fourth-quarter update to its 2015-2016 plan. In low-income housing tax credit news, he discusses the Federal Housing Finance Agency raising multifamily caps for Fannie Mae and Freddie Mac. He also discusses what two California housing agencies recommend to address the issue of high development costs when building affordable housing. In new markets tax credit news, he talks about the CDFI Fund's NMTC Public Data Release: 2003-2014 Summary Report. He also shares briefly how much qualified equity investment was issued in the CDFI Fund's latest qualified equity investment issuance report. In the historic tax credit section, he announces the 2016 winners of the Novogradac Journal of Tax Credit Historic Rehabilitation Awards. He closes out with renewable energy tax credit news, where he shares findings from the U.S. Department of Energy 2015 Wind Technologies Market Report.
Congress returns on 8 September to legislative, budgetary deadlines – Tax Court in Altera rules stock-based compensation costs not included in cost pool for QCSAs subject to 1995 cost-sharing regulations -- IRS Notice 2015-54 announces forthcoming regulations on partnership nonrecognition of property contributions -- IRS recharacterizes intercompany referral fee income, reallocates intercompany referral fee expenses -- IRS updates procedures for competent authority assistance -- IRS issues updated guidance on requesting and obtaining an APA -- IRS 2015-2016 Priority Guidance Plan contains new international tax projects – OECD issues report on implementing CbC standard.
In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, begins with an update on what the IRS included in its 2015-2016 Priority Guidance Plan. In the low-income housing tax credit segment, he discusses a recent report on how housing finance agencies are faring with a shift in multifamily subsidy types. Then, he talks about the proposed selection process for the third and final round of the Promise Zones Initiative. In the same section, he shares an opportunity to learn about low-income housing tax credit compliance rules and strategies. In new markets tax credit news, he shares the monthly Qualified Equity Investment Issuance or QEI report update. In the historic tax credit section, he discusses the latest meeting of the Advisory Council on Historic Preservation. In the renewable energy tax credit section, he talks about the amount of wind energy generation capacity installed during the second quarter of this year and how renewable energy tax credits helped fuel that growth.
In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, begins with an update on what the IRS included in its 2015-2016 Priority Guidance Plan. In the low-income housing tax credit segment, he discusses a recent report on how housing finance agencies are faring with a shift in multifamily subsidy types. Then, he talks about the proposed selection process for the third and final round of the Promise Zones Initiative. In the same section, he shares an opportunity to learn about low-income housing tax credit compliance rules and strategies. In new markets tax credit news, he shares the monthly Qualified Equity Investment Issuance or QEI report update. In the historic tax credit section, he discusses the latest meeting of the Advisory Council on Historic Preservation. In the renewable energy tax credit section, he talks about the amount of wind energy generation capacity installed during the second quarter of this year and how renewable energy tax credits helped fuel that growth.
Status update on US tax reform -- IRS opens online FATCA registration system -- US, Cayman Islands initial FATCA Model I IGA -- IRS 2013-2014 Priority Guidance Plan released -- IRS finalizes certain cost sharing regulations on determining taxable income -- US-Belgium competent authority agreement released
In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, discusses tax expenditures, sequestration, tax reform and charitable contributions, a Congressional Budget Office economic outlook for 2013 though 2023, smart growth and sustainable communities, the nomination of Jack Lew for Treasury Secretary and the president's State of the Union address. In historic tax credit news, he reports on the president's nomination of Sally Jewell for Secretary of the Interior and a Missouri Senate Appropriation Committee hearing on state tax credit programs. In low-income housing tax credit news, he discusses IRS Notice 2013-9 and Hurricane Sandy, the Treasury's Priority Guidance Plan, and a Mississippi bill that would reduce taxes for affordable housing properties. In new markets tax credit news, he alerts listeners to CDFI Fund listening sessions, recertification guidelines for CDFIs, qualified equity investment issuance for January and an upcoming CDFI Fund Advisory Board meeting. In renewable energy tax credit news, he discusses phase two of the Section 48C Advance Energy Manufacturing Tax Credit program and two solar tax credit bills in Hawaii.
In this week's Tax Credit Tuesday podcast, Michael J. Novogradac, CPA, discusses tax expenditures, sequestration, tax reform and charitable contributions, a Congressional Budget Office economic outlook for 2013 though 2023, smart growth and sustainable communities, the nomination of Jack Lew for Treasury Secretary and the president's State of the Union address. In historic tax credit news, he reports on the president's nomination of Sally Jewell for Secretary of the Interior and a Missouri Senate Appropriation Committee hearing on state tax credit programs. In low-income housing tax credit news, he discusses IRS Notice 2013-9 and Hurricane Sandy, the Treasury's Priority Guidance Plan, and a Mississippi bill that would reduce taxes for affordable housing properties. In new markets tax credit news, he alerts listeners to CDFI Fund listening sessions, recertification guidelines for CDFIs, qualified equity investment issuance for January and an upcoming CDFI Fund Advisory Board meeting. In renewable energy tax credit news, he discusses phase two of the Section 48C Advance Energy Manufacturing Tax Credit program and two solar tax credit bills in Hawaii.
Michael J. Novogradac, CPA, reviews last week's State of the Union Address. He also discusses the IRS's updated Priority Guidance Plan and a Senate Finance Committee hearing on tax extenders and tax reform. Then, he examines proposals to change the tax treatment of carried interest and reviews a bill in Indiana that would change how property taxes are assessed for low-income housing tax credit properties. Next, he shares the findings of the American Wind Energy Association's fourth quarter market report. Then, he discusses the next meeting of the Advisory Council on Historic Preservation and news from Missouri, where lawmakers have again begun to debate state tax credits. Finally, he considers legislation in Hawaii intended to make the state more attractive for new markets tax credit investing.