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 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.

EY ITTS Washington Dispatch, June 2023

A monthly review of US international tax-related developments. In this edition: US Congress passes debt ceiling bill, averts possible default – House Ways &amp; 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 Congress passes debt ceiling bill, averts possible default – House Ways &amp; 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.

EY ITTS Washington Dispatch, May 2023

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: 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.

EY ITTS Washington Dispatch, April 2023

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 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.

EY ITTS Washington Dispatch, March 2023

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: 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.

EY ITTS Washington Dispatch, February 2023

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: 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.

EY ITTS Washington Dispatch, January 2023

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: 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.

EY ITTS Washington Dispatch, December 2022

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: 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.

EY ITTS Washington Dispatch, November 2022

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: 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.

EY ITTS Washington Dispatch, October 2022

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.

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.

EY ITTS Washington Dispatch, September 2022

The Ernst &amp; Young ITS Washington Dispatch brings you the latest developments in US tax news.

Ernst & Young ITTS Washington Dispatch

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&amp;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

ITS Washington Dispatch, November  2018

OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments on US Section 59A BEAT regulations – IRS APMA releases Functional Cost Diagnostic Model for certain APAs – IRS requiring TP teams to consult with APMA in certain cases – IRS releases 2018 APA results – US, India sign CbC exchange agreement – OECD releases beneficial ownership toolkit

OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments on US Section 59A BEAT regulations – IRS APMA releases Functional Cost Diagnostic Model for certain APAs – IRS requiring TP teams to consult with APMA in certain cases – IRS releases 2018 APA results – US, India sign CbC exchange agreement – OECD releases beneficial ownership toolkit

EY ITS Washington Dispatch, March 2019

US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable return of capital - DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations - Ninth Circuit withdraws opinion reversing Tax Court in Altera — US Tax Court rules Section 1446 W/H tax liability is a partnership item -- Eighth Circuit vacates Tax Court opinion in Medtronic, remands to Tax Court for further consideration -- OECD releases fourth batch of peer review reports on Action 14

ITS Washington Dispatch, August  2018

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

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

EY ITS Washington Dispatch, December 2018

US House Republicans release tax reform 2.0 framework -- IRS issues final anti-corporate inversion regulations -- Proposed repatriation transition tax regulations release imminent; Treasury official offers insights on other international projects -- IRS denies DRD to affiliated group by treating swap on stock index as SSRP regarding single issue of stock -- IRS announces additional international compliance campaigns -- Treasury FATCA report finds fault with IRS -- New IRS guide on transfer pricing examinations released -- OECD releases draft on transfer pricing aspects of financial transactions -- OECD Secretary-General sends G20 finance ministers annual BEPS progress report

ITS Washington Dispatch, July  2018

Most TCJA international proposed regulations out by year-end -- IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS announces changes to Section 965 transition tax rules affecting basis election deadline, aggregate foreign cash position -- 2018 QI, W/H foreign partnership and W/H Foreign Trust application deadline 16 November 2018 -- IRS issues guidance for REITs on certain income inclusions from foreign corps -- IRS to move on W/H tax campaigns in 2019 -- US reaffirms opposition to unilateral digital tax measures -- US, Israel to review updating tax treaty -- OECD on track for digital tax framework -- OECD releases 2017 MAP statistics

ITS Washington Dispatch, October  2018

Tax agenda uncertain in new Congress -- Final IRS Section 965 transition tax regulations largely follow proposed rules, but include significant changes -- IRS releases final Form 8990 and instructions -- Argentine inflation may have US tax considerations for taxpayers with Argentine operations -- OECD releases policy note addressing tax challenges of digitalization -- OECD issues 2018 progress report on preferential regimes -- OECD BIAC issues tax principles for digital economy

Tax agenda uncertain in new Congress -- Final IRS Section 965 transition tax regulations largely follow proposed rules, but include significant changes -- IRS releases final Form 8990 and instructions -- Argentine inflation may have US tax considerations for taxpayers with Argentine operations -- OECD releases policy note addressing tax challenges of digitalization -- OECD issues 2018 progress report on preferential regimes -- OECD BIAC issues tax principles for digital economy

EY ITS Washington Dispatch, January 2019

IRS releases final Section 956 regulations, generally follow proposed rules with two major modifications – IRS finalizes certain temporary FX regulations – IRS proposed regulations under Section 1446(f) clarify scope of W/H on transfers of partnership interests – EC comments on US FDII proposed regulations – US reiterates opposition to unilateral digital proposals – Puerto Rico, USVI developments highlighted

IRS releases final Section 956 regulations, generally follow proposed rules with two major modifications – IRS finalizes certain temporary FX regulations – IRS proposed regulations under Section 1446(f) clarify scope of W/H on transfers of partnership interests – EC comments on US FDII proposed regulations – US reiterates opposition to unilateral digital proposals – Puerto Rico, USVI developments highlighted

EY ITS Washington Dispatch, May 2019

Temporary and proposed DRD regulations reflect GILTI-centric view of TCJA’s international tax rules – US government issues final and proposed GILTI and subpart F regulations – IRS issues proposed regulations under Sections 954 and 958; consequences for subpart F and GILTI regimes – IRS issues proposed regulations on FIRPTA tax exception for foreign pension funds’ interests in US real property – DC Circuit affirms Grecian Magnesite Mining – Ninth Circuit again reverses Tax Court in Altera cost sharing case – US Senate Foreign Relations Committee reports out tax protocols to treaties with Japan, Luxembourg, Spain and Switzerland – OECD digital workplan envisions global agreement on new rules for multinational taxation – G20 Finance Ministers and Central Bank Governors welcome progress on addressing tax challenges from digitalization

Temporary and proposed DRD regulations reflect GILTI-centric view of TCJA’s international tax rules – US government issues final and proposed GILTI and subpart F regulations – IRS issues proposed regulations under Sections 954 and 958; consequences for subpart F and GILTI regimes – IRS issues proposed regulations on FIRPTA tax exception for foreign pension funds’ interests in US real property – DC Circuit affirms Grecian Magnesite Mining – Ninth Circuit again reverses Tax Court in Altera cost sharing case – US Senate Foreign Relations Committee reports out tax protocols to treaties with Japan, Luxembourg, Spain and Switzerland – OECD digital workplan envisions global agreement on new rules for multinational taxation – G20 Finance Ministers and Central Bank Governors welcome progress on addressing tax challenges from digitalization

EY ITS Washington Dispatch, June 2019

The Ernst &amp; 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.

The Ernst &amp; 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.

EY ITS Washington Dispatch, August 2019

US House approves ‘tax reform 2.0’ legislation – US government issues proposed GILTI regulations – Treasury and IRS propose removing Section 385 debt/equity documentation requirements -- IRS releases draft Form 8991 for TCJA’s BEAT – IRS grants relief to RICs from Section 4982 excise tax for Section 965 inclusions – IRS to delay Section 871(m) regulations effective / applicability date two years – IRS issues guidance on REITS on income inclusions from foreign corporations -- IRS announces new compliance campaigns – OECR issues more CbCR guidance, updated exchange relationships

ITS Washington Dispatch, September  2018

US Senate approves amending tax protocols with Luxembourg, Switzerland, Japan and Spain – US considers retaliation against France’s new DST – IRS issues proposed PFIC regulations – IRS releases final regulations for allocating partnerships’ creditable foreign tax expenditures – IRS sending warning letters to virtual currency owners – IRS issues information on Section 965 filing and payment – Altera Corporation files petition for rehearing of cost sharing case in Ninth Circuit

US Senate approves amending tax protocols with Luxembourg, Switzerland, Japan and Spain – US considers retaliation against France’s new DST – IRS issues proposed PFIC regulations – IRS releases final regulations for allocating partnerships’ creditable foreign tax expenditures – IRS sending warning letters to virtual currency owners – IRS issues information on Section 965 filing and payment – Altera Corporation files petition for rehearing of cost sharing case in Ninth Circuit

EY ITS Washington Dispatch, July 2019

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&amp;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

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&amp;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

EY ITS Washington Dispatch, Feburary 2019

US Congressional tax writers concerned over unilateral digital taxation proposals – IRS publishes revised 2019 Tax Treaty Table 1 – No delay in Section 965 final regulations effective date – IRS LB&amp;I announces new compliance campaigns on transfer pricing and information reporting – IRS may use APMA FCD Model in some exams – GAO issues report on FATCA implementation – OECD FTA publishes 7 reports on tax administration – OECD FTA announces ICAP 2.0 – UN Subcommittee issues paper on digital taxation  

US Congressional tax writers concerned over unilateral digital taxation proposals – IRS publishes revised 2019 Tax Treaty Table 1 – No delay in Section 965 final regulations effective date – IRS LB&amp;I announces new compliance campaigns on transfer pricing and information reporting – IRS may use APMA FCD Model in some exams – GAO issues report on FATCA implementation – OECD FTA publishes 7 reports on tax administration – OECD FTA announces ICAP 2.0 – UN Subcommittee issues paper on digital taxation

EY ITS Washington Dispatch, April 2019

US Congressional leaders talk tax reform 2.0 -- US Supreme Court overturns physical presence nexus standard; major implications for sales to the United States -- IRS updates Section 965 transition tax FAQs to include late-payment penalty, filing relief -- IRS announces additional delay of Section 987 FX regulations -- US officials offer TCJA international regulatory update -- IRS finalizing 2016 proposed FATCA regulations; portal for certifications this summer -- OECD issues guidance on hard-to-value intangibles, transactional profit split method -- OECD not in competition with EU on digital taxation, official says

ITS Washington Dispatch, June  2018

US officials offer insights, timelines on upcoming TCJA guidance -- House Republicans, Trump Administration discuss ‘phase-two’ tax reform -- IRS announces forthcoming regulations expanding Section 956 exception to definition of US property -- Final anti-inversion rules may be released in June – US government releases offer timing for TCJA international tax guidance -- IRS announces new template for APAs -- OECD releases first annual peer review report (Phase 1) on Action 13 -- OECD may revise Transfer Pricing Guidelines -- UN releases updated Model Tax Treaty

ITS Washington Dispatch, May  2018

The Ernst &amp; Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new anti-abuse rule targeting certain ‘GILTI gap period’ transactions – Taxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24 – IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions – IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act – IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions – IRS withdraws 2004 Notice on ‘Midco’ transactions – IRS releases FAQs on transfer pricing documentation best practices – IRS issues annual APA report for 2019 – IRS updates FATCA FAQs – OECD BEPS 2.0 project to continue on current timelines – OECD issues guidance on impact of the COVID-19 crisis on treaty-related issues – OECD releases second batch of Stage 2 peer review reports on dispute resolution.

The Ernst &amp; Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new anti-abuse rule targeting certain ‘GILTI gap period’ transactions – Taxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24 – IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions – IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act – IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions – IRS withdraws 2004 Notice on ‘Midco’ transactions – IRS releases FAQs on transfer pricing documentation best practices – IRS issues annual APA report for 2019 – IRS updates FATCA FAQs – OECD BEPS 2.0 project to continue on current timelines – OECD issues guidance on impact of the COVID-19 crisis on treaty-related issues – OECD releases second batch of Stage 2 peer review reports on dispute resolution.

EY ITS Washington Dispatch, April 2020

The Ernst &amp; 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 &amp; 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.

EY ITS Washington Dispatch, March 2020

The Ernst &amp; 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.

The Ernst &amp; 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.

EY ITS Washington Dispatch, February 2020

The Ernst &amp; Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US officials offer new insights for coming international tax guidance – IRS releases final regulations on US partner contributions to partnerships with related foreign partners – Final FATCA and chapter 3 regulations issued – IRS will entertain cryptocurrency PLRs – IRS will consider certain requests for double taxation relief due to Section 965 repatriation – IRS rules target’s capitalized transaction costs do not create a separate and distinct intangible asset – OECD announces renewed IF commitment for 2020 consensus on new international tax rules under BEPS 2.0 – OECD releases additional guidance on CbCR, summary of related notification requirements – OECD releases third peer review report on Action 5 on the exchange of tax rulings.

The Ernst &amp; Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US officials offer new insights for coming international tax guidance – IRS releases final regulations on US partner contributions to partnerships with related foreign partners – Final FATCA and chapter 3 regulations issued – IRS will entertain cryptocurrency PLRs – IRS will consider certain requests for double taxation relief due to Section 965 repatriation – IRS rules target’s capitalized transaction costs do not create a separate and distinct intangible asset – OECD announces renewed IF commitment for 2020 consensus on new international tax rules under BEPS 2.0 – OECD releases additional guidance on CbCR, summary of related notification requirements – OECD releases third peer review report on Action 5 on the exchange of tax rulings.

EY ITS Washington Dispatch, January 2020

The Best Multi-Part Documentaries, with documentaries on Obama, Federer vs Nadal, the making of Star Wars, Netflix vs Blockbuster and more. Add episodes you're interested into your queue below!

Best Multi-Part Documentaries

The best philosophy podcast episodes. Asking questions about how to live a better life, what it means to be and do good, to the idea of God. This topic includes episodes that bring about important questions that everyone should be asking themselves. Add episodes you're interested into your queue below!