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

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