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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

A review of the week's major US international tax-related news. In this edition: IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One Multilateral Convention on Amount A moving forward.

A review of the week's major US international tax-related news. In this edition: US Congress returns from spring recess; no movement on tax bill – IRS releases latest APA report – OECD misses deadline on BEPS Pillar One MLC on Amount A.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.

A review of the week's major US international tax-related news. In this edition: Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.

A review of the week's major US international tax-related news. In this edition: President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.

A review of the week's major US international tax-related news. In this edition: President Biden delivers State of the Union address, offers new tax proposals – US House Ways & Means Tax Subcommittee holds hearing on OECD BEPS Pillar 1 – OECD Secretary-General Tax Report offers insights on BEPS project.

A review of the week's major US international tax-related news. In this edition: US IRS exempts Form 1042 electronic filing in 2024 for US and nonresident withholding agents – IRS will no longer issue significant single issue PLRs – US Senate approves nomination of new IRS Chief Counsel – EY launches new tax podcast series.

A review of the week's major US international tax-related news. In this edition: US Congress to return to session – OECD releases final guidance on BEPS Pillar One Amount B on baseline distributions.

A review of the week's major US international tax-related news. In this edition: US House and Senate recess; focus to turn to approaching government funding deadlines, tax package possible – IRS sending info request letters to US-based subsidiaries of foreign-owned corporations re intercompany transaction pricing – IRS plans to finalize proposed FX regulations by year-end – US signs extension to moratorium agreement on unilateral measures, including DSTs.

A review of the week's major US international tax-related news. In this edition: US House-passed tax package may require Senate Finance Committee markup – Senate begins two-week recess.

A review of the week's major US international tax-related news. In this edition: US House of Representatives passes tax package; Senate action unclear – IRS expects to finalize two sets of Section 367 proposed regulations in first half of 2024 – Senate Finance Committee again approves IRS Chief Counsel nomination – OECD releases first statistics on ICAP.

A review of the week's major US international tax-related news. In this edition: US tax package may get House floor vote week of 29 January, future in the Senate uncertain – US officials offer international tax regulatory update on CAMT, stock buyback excise tax, cloud computing and PTEP rules – OECD releases working paper on global minimum tax and taxation of MNE profit.  

A review of the week's major US international tax-related news. In this edition: House and Senate tax writers release $78 billion tax package – Congress passes CR to fund the government – IRS announces cryptocurrency transactions do  not have to be reported until regulations issued.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess, government spending and possible tax package on the agenda – IRS to release CAMT package shortly – Treasury official offers US position on BEPS Pillar One – OECD Working Paper addresses global minimum tax and MNE taxation – EY releases 2024 International Tax and Transfer Pricing Survey, respondents say BEPS 2.0 project expands risk of double taxation.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty ceased to have effect – IRS issues interim guidance on basis adjustments re: inbound liquidations or asset reorganizations – IRS updates list of treaty partner countries – IRS broadens scope of possible private letter rulings.

A review of the week's major US international tax-related news. In this edition: OECD/G20 Inclusive Framework releases BEPS 2.0 Pillar Two Administrative Guidance on GloBE rules – OECD announces new BEPS Pillar One MLC timeline – US-Chile income tax treaty enters into force – US Congress adjourns until January 2024 – Congressional JCT releases Bluebook on tax legislation in 117th Congress.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issue FTC guidance addressing BEPS 2.0 Pillar Two GloBE top-up taxes – IRS CAMT regs delayed to 2024, but CAMT Notice released – IRS announces active compliance campaign on CAMT – Stock buyback excise tax guidance still on track for 2023 release – IRS official says PTEP targeted notice coming soon – US government plans to finalize foreign government investment exemption regs in 2024 – IRS working on crypto-asset reporting framework regulations.

A review of the week's major US international tax-related news. In this edition: US Supreme Court holds oral arguments in Moore transition tax case – Congress set to adjourn next week.

A review of the week's major US international tax-related news. In this edition: US-Taiwan tax bill moves forward – OECD to release additional BEPS 2.0 Pillar Two guidance by year-end.

A review of the week's major US international tax-related news. In this edition: Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.

A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.

A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

A review of the week's major US international tax-related news. In this edition: US House of Representatives chooses new speaker – US-Chile tax treaty’s reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now expected in early 2024 – Cyprus announces Cyprus-US CAA for exchange of CbC reports will be effective for RFYs starting on/after 1 January 2023 – OECD BEPS IF considering Pillar 2 guidance on treatment of deferred tax assets in countries with federal and subnational taxes

A review of the week's major US international tax-related news. In this edition: US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce ‘U.S.-Taiwan Expedited Double Tax Relief Act’.

A review of the week's major US international tax-related news. In this edition: OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.

A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada’s DST proposal.

A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer “Alternative A” in scoping rules for Amount B in BEPS Pillar One

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and “promoters abusing tax rules on the books.” 

A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

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 review of the week's major US international tax-related news. In this edition: IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

A review of the week's major US international tax-related news. In this edition: Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

A review of the week's major US international tax-related news. In this edition: Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

A review of the week's major US international tax-related news. In this edition: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS 2.0 Pillars One and Two technical documents – House Ways and Means Tax Subcommittee hearing on BEPS sees Republicans criticize Biden Administration’s policy – IRS PTEP proposed regs on track for release later this year.

A review of the week's major US international tax-related news. In this edition: OECD releases outcome statement on BEPS 2.0 Pillars One and Two progress – US Congress considering action on a US-Taiwan tax agreement – US senators reissue crypto-assets legislative proposal, request more information – Joint Committee on Taxation issues digital asset report.

A review of the week's major US international tax-related news. In this edition: US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.

A review of the week's major US international tax-related news. In this edition: US Senate approves US-Chile income tax treaty – Congressional Joint Committee on Taxation releases revenue analysis of BEPS Pillar Two global minimum tax – BEPS Pillar One and Pillar Two developments expected in coming weeks.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee approves three separate tax packages – Proposed US-Chile income tax treaty may have final US Senate vote as early as 21 June – OMB’s OIRA will no longer review Treasury tax regulations – OECD officials comment on BEPS Pillars One and Two.  

A review of the week's major US international tax-related news. In this edition: Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.  

A review of the week's major US international tax-related news. In this edition: US Congress passes debt ceiling legislation – US House Ways and Means Committee Republicans introduce legislation targeting OECD BEPS 2.0 Pillar Two Undertaxed Profits Rule – US Senate Foreign Relations Committee reports out proposed US-Chile income tax treaty – US House members introduce resolution calling for legislation to prevent US-Taiwan double taxation.  

A review of the week's major US international tax-related news. In this edition: US House Republicans to introduce anti-BEPS Pillar Two legislation – G-7 Finance Ministers welcome OECD progress report, reiterate commitment to BEPS Pillars One and Two – IRS to hire additional transfer pricing and competent authority staff, will expand CAP, APA and pre-filing programs.

A review of the week's major US international tax-related news. In this edition: OECD official offers insights on BEPS Pillar One and Pillar Two – US Senate Foreign Relations Committee may act on proposed US-Chile tax treaty – IRS official clarifies coming PTEP regulations in regard to partnerships.

A review of the week's major US international tax-related news. In this edition: President Biden, congressional leaders in debt ceiling talks, but no breakthroughs yet – US Senate Finance Committee holds hearing on cross-border pharma manufacturers and US international tax policy – US government officials discuss CAMT guidance, another notice coming – New US-Israel tax treaty in the works – US, Swiss tax protocol negotiations progressing.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed regulations on IP repatriation subject to Section 367(d) – Bipartisan US senators introduce bill to authorize negotiations with Taiwan to conclude tax agreement – US, Norway conducting tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: US House passes debt ceiling, spending bill – Treasury says no decision on interim CAMT guidance – IRS updates crypto notice – OECD to release BEPS Pillar Two qualified domestic minimum top-up tax safe harbor by summer.

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans introduce debt limit, spending bill – SEC Chairman defends agency’s authority over cryptocurrency products.

A review of the week's major US international tax-related news. In this edition: US Congress returns from recess; will need to address debt ceiling and spending – IRS issues proposed rules on micro-captive transactions as listed transactions.

A review of the week's major US international tax-related news. In this edition: IRS will provide transition period for documentation requirements for FTC "single-country exception" – US Tax Court rules IRS lacks authority to assess penalties under Section 6038(b) – US, Germany sign competent authority arrangement on automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US’ OECD contribution.

A review of the week's major US international tax-related news. In this edition: IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary testifies before Senate Finance Committee on FY ‘24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira’s hyperinflationary status has US tax consequences.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

A review of the week's major US international tax-related news. In this edition: IRS will issue initial guidance on how far back to apply basis adjustments to arrive at “opening” books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US shareholder for Section 951(a)(2)(B) purposes.

A review of the week's major US international tax-related news. In this edition: IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

A review of the week's major US international tax-related news. In this edition: President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, ‘billionaire surtax’ – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs, competent authority assistance.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

A review of the week's major US international tax-related news. In this edition: US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.

A review of the week's major US international tax-related news. In this edition: Rep. Kevin McCarthy new House Speaker, Rep. Joshua Smith named chairman of House Ways and Means Committee – IRS CAMT guidance addresses questions, leaves open issues.

A review of the week's major US international tax-related news. In this edition: IRS issues interim guidance on application of new corporate alternative minimum tax – IRS releases interim guidance on excise tax on certain corporate stock buybacks – IRS releases final regulations on FIRPTA tax exception for qualified foreign pension funds and qualified controlled entities.

A review of the week's major US international tax-related news. In this edition: US Congress passes $1.7 trillion spending bill; no Tax Title – Treasury plans guidance on CAMT and stock buyback excise tax by year-end – IRS announces it will issue proposed regulations amending final Section 1446(f) final withholding regulations for PTPs – Treasury official says GILTI will need to be reformed – Congressional Republican lawmakers voice concerns over BEPS Pillar Two Undertaxed Profits Rule – OECD issues (i) consultation document on Pillar One MLI re: DSTs; (ii) consultation document on Pillar Two GloBE information return; (iii) consultation document on Pillar Two tax certainty for GloBE rules; and (iv) guidance on Pillar Two safe harbors and penalty relief.

A review of the week's major US international tax-related news. In this edition: US Congress passes temporary stopgap spending measure to facilitate omnibus bill negotiation; Tax Title uncertain – IRS releases Rev. Ruling 2022-43 with final qualified intermediary   withholding agreement – IRS issues proposed regulations on single-entity treatment of consolidated groups for purposes of Section 951 – FinCEN further extends FBAR filing deadline – FinCEN issues proposed regulations on beneficial ownership – OECD releases consultation document on Amount B of BEPS 2.0 Pillar One – EU adopts Directive on global minimum tax.

A review of the week's major US international tax-related news. In this edition: US Congress grapples with government funding in lame duck, will impact tax package options – US, Croatia sign tax treaty – OECD releases consultation document on design elements of BEPS Pillar One Amount B re: simplification of transfer pricing rules.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame duck session; business tax measures could be included in omnibus spending bill – IRS Corporate Alternative Minimum Tax guidance possible before year-end.

A review of the week's major US international tax-related news. In this edition: IRS pivoting to cryptocurrency, opens digital asset project office – IRS drafting questions on cryptocurrency, digital assets for corporate and partnership returns.

A review of the week's major US international tax-related news. In this edition: Republicans take House, Democrats hold Senate; lame-duck legislation remains uncertain – IRS issues highly anticipated foreign tax credit proposed regulations – IRS proposed regulations under Section 367(d) will be released early next year – IRS considering use of economic substance in transfer pricing audits, even with TP documentation.

A review of the week's major US international tax-related news. In this edition: US congressional lame duck tax legislation unclear amid midterm election uncertainty – Proposed foreign tax credit regulations coming soon, limited CAMT guidance this year – IRS releases 2022-2023 Priority Guidance Plan – Congressional ranking Republicans urge reversal of decision to terminate US-Hungary tax treaty – Biden Administration nominates new IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Treasury warns there may be little guidance re new corporate minimum tax and stock buyback tax before effective date – No transition period or delay in implementation date for final Section 1446(f) withholding regulations – IRS expects more penalties in transfer pricing cases – House Ways and Means Committee Republicans request Treasury retain all documents, communications re OECD BEPS 2.0 Pillar One Agreement.

A review of the week's major US international tax-related news. In this edition: US Treasury working on ‘prophylactic’ measures to address new tax regimes in the context of future tax treaties – US, Croatia to sign tax treaty before year-end – Treasury official expects proposed crypto regulations release in 2022 – OECD wants broad acceptance of its Crypto Asset Reporting Framework.

A review of the week's major US international tax-related news. In this edition: IRS proposed foreign tax credit regulations ‘weeks away’ – 2006 proposed PTEP regs officially withdrawn, new regs in first half of 2023 – IRS official offers update on new corporate alternative minimum tax – IRS plans to reconsider APA revenue procedure guidance in light of recent Eaton Corporation decision.

A review of the week's major US international tax-related news. In this edition: OECD releases new global tax transparency framework for crypto-assets, amendments to Common Reporting Standard – IRS to request Sponsoring Entities cancel their FATCA agreement if they fail to meet Sponsoring Entity requirements.

A review of the week's major US international tax-related news. In this edition: OECD Inclusive Framework on BEPS releases new consultation on Pillar One Amount A, other BEPS related documents – OECD will release amendments to crypto-asset reporting framework, Common Reporting Standard on 10 October.

A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund federal government, recesses until after midterm elections – EY comments on Inflation Reduction Act’s CAMT in M&A context – FinCEN issues final beneficial ownership rule – OECD’s FTA issues bilateral APA manual.

A review of the week's major US international tax-related news. In this edition: House Republican leadership set to release “Commitment to America” platform – IRS provides guidance on applying noncompulsory payment rules in FTC regs to amended tax decrees between MNEs and Puerto Rico tax authority – IRS officials offer updates on international issues and regulations.

A review of the week's major US international tax-related news. In this edition: US Congress focused on CR to extend government funding beyond 30 September; post-midterm year-end bill could address tax – House Republicans poised to release “Commitment to America” November election platform – OECD holds public consultation on Progress Report on BEPS Pillar One Amount A.

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-midterm election session – Treasury official offers international regulatory update; PTEP regs coming in Q1 2023 – US tax treaty negotiations with Switzerland, Israel to begin; pending treaties being updated – 6th Circuit rules IRS bears burden of proof to cancel APAs – OECD considering two permanent safe harbors re BEPS 2.0 Pillar Two global minimum tax rules – OECD’s Pascal Saint Amans to step down.

A review of the week's major US international tax-related news. In this edition: IRS Notice 2022-36 penalty relief applies to certain international tax information returns – OECD releases public comments on Progress Report on Amount A of BEPS Pillar One – EY concludes Amount A of Pillar One will result in a few mature market jurisdictions gaining additional taxing rights, but most others receiving little benefit.

A review of the week's major US international tax-related news. In this edition: IRS to delay effective date for aspects of Section 871(m) regulations, further extend transition relief – IRS extends deadline for unfiled 2019 and 2020 returns, penalty relief for certain 2019 and 2020 returns – US Tax Court increases Medtronic royalty rate under unspecified TP method.

A review of the week's major US international tax-related news. In this edition: President Biden signs Inflation Reduction Act of 2022 into law; includes new 15% corporate alternative minimum tax – Inflation Reduction Act includes unprecedented energy and climate provisions – Stock buyback provision in Inflation Reduction Act may have broader implications – IRS funding in Inflation Reduction Act may increase scrutiny of transfer pricing cases – Treasury and IRS to extend applicability date of 2016 final Section 987 FX regulations additional year.

A review of the week's major US international tax-related news. In this edition: Senate approves Inflation Reduction Act of 2022 – President Biden signs CHIPS and Science Act.

A review of the week's major US international tax-related news. In this edition: US Senate Democrats reach agreement on health, climate and tax budget reconciliation bill; moves to Senate floor 6 August – House Ways and Means Committee Republicans introduce resolution to compel Treasury to produce documents showing effects of BEPS 2.0 Pillar One rules.

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740 billion climate/energy, health and tax reconciliation bill – Congress passes $280 billion CHIPS and Science Act; goes to President for signature – IRS makes substantive changes to final US foreign tax credit regulations.

A review of the week's major US international tax-related news. In this edition: US budget reconciliation legislation uncertainty continues – Treasury confirms termination of US-Hungary tax treaty.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington following 4 July recess; Sen. Manchin will not support climate measures, tax increases in budget reconciliation following US inflation report – IRS releases proposed FX regulations – US plans to terminate US-Hungary tax treaty – OECD releases Progress Report on Amount A of Pillar One.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats continue to negotiate slimmed-down budget reconciliation bill – OECD officials provide BEPS 2.0 update at annual tax conference – US officials discuss BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin meet again to discuss budget reconciliation – US Supreme Court accepts FBAR case for review – IRS plans to expand transfer pricing audit coverage.

A review of the week's major US international tax-related news. In this edition: President Biden expresses confidence budget reconciliation bill will pass Congress; meetings held – Congressional Republicans propose anti-inflationary measures, including tax cuts – Republican House Ways and Means Committee members ask Treasury to delay final foreign tax credit regulations – OECD official urges ‘first-movers’ on BEPS 2.0 Pillar Two.

A review of the week's major US international tax-related news. In this edition: US Sen. Manchin says no deal yet on limited budget reconciliation bill – Treasury Secretary comments on BEPS Pillar One – Treasury official offers insights on computing CFCs’ minimum taxes in BEPS Pillar Two – Treasury Secretary says no delay in final foreign tax credit regulations – 28 CFOs comment on final foreign tax credit rules.

A review of the week's major US international tax-related news. In this edition: Congress returns from Memorial Day holiday to budget reconciliation uncertainty – Support Ukraine Through Our Tax Code Act introduced in the House – US government supports excluding reinsurance and asset management from the BEPS 2.0 Pillar One – OECD initiates public consultation on BEPS Pillar One tax certainty – OECD Secretary General predicts BEPS 2.0 practical implementation from 2024 onwards.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats move “soft deadline” for BBB action to August recess – US Treasury offers insights to future FTC guidance – OECD officials discuss BEPS 2.0 progress.

A review of the week's major US international tax-related news. In this edition: US House leaders hope to pass “China competitiveness” bill before 4 July recess – Senate introduces bill to disallow foreign tax credits (FTCs) for taxes paid to Russia or Belarus – Treasury, IRS considering changes to FTC regulations – IRS proposed Section 1256 regulations on FX contracts set for release in coming weeks, Section 987 rules to follow – IRS issues GLAM on allocation and apportionment of deferred compensation expense for FDII deductions, reverses prior guidance – Treasury, OECD officials offer BEPS 2.0 insights.

A review of the week's major US international tax-related news. In this edition: Little action on budget reconciliation as US Congress focuses on ‘China competitiveness’ legislation – Treasury official reveals government working on “Killer B” cross-border triangular reorg regs, Section 367(d) rules involving transferred IP repatriated to US.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary calls on Congress to pass BEPS-like minimum corporate tax – Treasury officials comment on BEPS 2.0 – IRS publishes changes to QI withholding agreement rules – IRS unclear on scope of financial transaction transfer pricing regulation project – US House Ways and Means Committee members request delay to implementation of final FTC regulations – First-ever US-Croatia income tax treaty under US State Department review.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington to budget reconciliation uncertainty; Senator Manchin offers high-level clarity – OECD holds public consultation on Implementation Framework for BEPS 2.0 Pillar Two GloBE Rules – OECD releases public comments on Draft Model Rules for Domestic Legislation on Scope under Pillar One.

A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington; Democrats may make one last attempt at reconciliation legislation – Biden Administration supports both BEAT repeal and replacement with UTPR and BBB’s BEAT reforms.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary says BEPS 2.0 will help global economies recover from COVID-19 pandemic, Ukraine crisis – IRS releases new Schedules K-2, K-3 FAQs – US Senate Foreign Relations Committee issues report on proposed US-Chile tax treaty.

A review of the week's major US international tax-related news. In this edition: Prospects for post-Build Back Better Act reconciliation bill uncertain – Senate bill would deny US FTCs for Russian taxes paid – OECD announces public consultation on draft model rules on scope of Amount A in BEPS 2.0 Pillar One.

A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY2023 budget with international tax proposals – US Senate Foreign Relations Committee approves US-Chile income tax treaty – OECD public consultation on crypto-asset reporting framework expected by end of May.

A review of the week's major US international tax-related news. In this edition: President Biden to release FY 2023 budget on 28 March – Sen. Manchin revives pared-down budget reconciliation talks – Final US FTC regulations will be amended to reflect BEPS 2.0 Pillar One and Pillar Two – Senate Foreign Relations Committee to take up US-Chile tax treaty, US-Croatia treaty talks in final stages – OECD initiates public consultation on crypto-asset reporting framework, amendments to CRS.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – OECD releases BEPS 2.0 Pillar Two commentary – US Senate Finance Committee Chairman supports tax sanctions for Russia and Belarus – IRS official recommends all taxpayers seeking PLRs should avail of new fast-track process.

A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – Treasury official confirms previously-taxed earnings and profits regulations coming in latter half of 2022 – IRS official says partial US FTC may only be available on foreign withholding on IP royalties in certain instances.

A review of the week's major US international tax-related news. In this edition: President Biden presents first State of the Union address; lists provisions but does not mention Build Back Better – Sen. Manchin says he could support limited reconciliation package focused on taxes, climate change and deficit reduction – Senate Democrats eye US-Russia tax treaty in response to Ukraine crisis.

A review of the week's major US international tax-related news. In this edition: OECD officials reconfirm ambitious BEPS 2.0 timeline; provide further details – OECD is finalizing tax reporting framework for cryptoassets.

A review of the week's major US international tax-related news. In this edition: US Senate mulls anti-inflation measures – IRS releases FAQs on transition relief for certain domestic partnerships and S corporations completing new Schedules K-2 and K-3 – Treasury official comments on future proposed regulations on cryptocurrency reporting requirements for brokers – OECD official concedes BEPS 2.0 Pillar One draft rules complexity – Republican Senate Finance Committee members concerned over BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US inflation report may affect size and scope of future social spending, climate and tax bill – Increasing signs Congress may act on year-end 2021 tax changes.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin reiterates need for wholly new spending and tax bill; Congress faces full agenda – OECD announces first wave of consultations on the BEPS 2.0 Pillar One rules, releases consultation document – OECD official reinforces BEPS 2.0 timeline.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin confirms Build Back Better discussions back on – Concern over double taxation if US GILITI unamended – Republican tax writers warn BEPS Pillars require  congressional action – Treasury releases final regulations on treatment of domestic partnerships under Section 958, proposed PFIC regulations – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework.

A review of the week's major US international tax-related news. In this edition: President Biden favors breaking up Build Back Better into smaller bills – OECD BEPS 2.0 Pillar Two model rules commentary expected in early February – OECD releases 2022 Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: No action on President Biden’s Build Back Better agenda as Congress pivots to other legislative priorities – Treasury developing interim guidance on cryptocurrency reporting.

A review of the week's major US international tax-related news. In this edition: Build Back Better Act faces uncertain path – Treasury and IRS release final foreign tax credit regulations – IRS finalizes rules addressing the tax consequences of the elimination of LIBOR and other interbank offered rates.

A review of the week's major US international tax-related news. In this edition: Senator Joe Manchin will not support Build Back Better Act; Majority Leader will bring forward ‘modified’ version of bill in new year – OECD releases Model Rules on the Pillar Two Global Minimum Tax.

A review of the week's major US international tax-related news. In this edition: US Senate will not take up Build Back America Act in 2021 – Updated Senate Finance Committee's title of the Build Back Better Act retains House’s international tax proposals, but with major technical changes – Final foreign tax credit regulations clear OMB, return for final Treasury review – OMB reviewing final regulations on interbank offered rates (IBORS) – OECD to release Pillar Two Global Anti-Base Erosion Model Rules on 20 December.

A review of the week's major US international tax-related news. In this edition: US Senate Democratic BBBA meetings with Parliamentarian concluded; bipartisan “Byrd bath” meetings begin next week – Senate Foreign Relations Committee Republicans urge vote on proposed 2010 US-Chile tax treaty – Treasury’s FinCEN published proposed regulations on beneficial ownership.

A review of the week's major US international tax-related news. In this edition: US Congress turns to Build Back Better reconciliation bill after recess – Final foreign tax credit regulations release before year-end -- US, India announce digital tax, trade action compromise – Technical aspects of model rules for OECD BEPS Pillar 2 complete; further Pillars’ consultation planned.

A review of the week's major US international tax-related news. In this edition: US, Turkey announce digital tax, trade action compromise – OECD committed to BEPS Pillars in effect by end of 2023 – US Congress in recess; Senate expected to take up House-passed Build Back Better Act after Thanksgiving break.

A review of the week's major US international tax-related news. In this edition: President Biden signs infrastructure legislation – House passes Build Back Better Act budget reconciliation bill, Senate consideration after Thanksgiving holiday – IRS releases new tool to support US withholding agents compliance with reporting, withholding re IRS Form 1042-S – IRS requests comments on Rev. Proc. 2015-41 regarding APAs and MAP applications and compliance.

A review of the week's major US international tax-related news. In this edition: President Biden to sign infrastructure legislation next week with crypto provisions; House Speaker wants reconciliation vote week of 15 November – Final foreign tax credit regulations expected before year-end – Proposed PTEP regulations moving forward.

A review of the week's major US international tax-related news. In this edition: US House poised to pass Build Back Better Act budget reconciliation bill, infrastructure legislation – IRS ILM concludes extended six-year assessment period under Section 6501(e)(1)(c) applies to entire tax liability, not just omitted subpart F and/or GILTI items.

A review of the week's major US international tax-related news. In this edition: New $1.75 trillion US budget reconciliation framework and legislative text released; tax items not fully settled.

A review of the week's major US international tax-related news. In this edition: Negotiations continue in congress to reach agreement on House reconciliation bill – Treasury releases joint statement with several countries on DST Agreement – IRS issues commodity derivatives private letter ruling – Platform for Collaboration on Tax enhances support to countries in the area of domestic resource mobilization during the COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Debate continues over size and scope of US budget reconciliation bill – G-20 Finance Ministers endorse BEPS 2.0 Pillar One and Pillar Two agreement – US officials discuss implementation of BEPS 2.0 – US to defer by one additional year applicability date of final Section 987 FX regulations, certain related final regulations – Cyprus clarifies Cyprus-US CAA for exchange of CbC reports.  

A review of the week's major US international tax-related news. In this edition: Inclusive Framework on BEPS announces agreement on Two Pillar solution – US Congressional Democrats’ dispute over size of Build Back Better budget reconciliation bill continues – OECD publishes two MLI opinions.

A review of the week's major US international tax-related news. In this edition: US Congress grapples over infrastructure, budget reconciliation legislation – G7 Finance Ministers make progress on BEPS 2.0 issues in lead up to October 2021 meetings -- IRS lists jurisdictions with which it has information exchange for reporting certain deposit interest paid.

A review of the week's major US international tax-related news. In this edition: White House, House and Senate Democrats discussing path forward on budget reconciliation bill – IRS APMA director warns taxpayers against unilateral relief.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee clears major tax bill to partially fund Build Back Better Act; includes major changes to US international tax rules – IRS seeing $1 billion MAP cases, LB&I official says.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee begins budget reconciliation markup – Treasury pushes for 21 percent minimum corporate tax on foreign earnings – Senate Finance Committee Chairman releases draft partnership tax legislation – Treasury official offers update on coming final foreign tax credit regulations – IRS releases 2021–2022 Priority Guidance Plan – IRS allows taxpayer to reverse "gap period" transaction through late CTB election.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee to begin markup the week of 6 September re: Budget Resolution – IRS articulates five-factor test in determining income inclusion of reimbursement payments – US, France sign joint statement on spontaneous exchange of CbC reports for FYs beginning 2020 and 2021.

A review of the week's major US international tax-related news. In this edition: US House passes FY 2022 budget resolution on path to trillion-dollar reconciliation bill; infrastructure vote no later than 27 September – Senate Finance Committee Chairman, committee members provide details on international tax framework proposals – IRS extends date for W/H on certain transfers, distributions related to publicly traded partnership interests to 1 January 2023.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to convene to consider FY 2021 Budget Resolution – US, Germany agree to share CbC reporting information.

A review of the week's major US international tax-related news. In this edition: US Senate passes $1.2 trillion infrastructure bill, $3.5 trillion budget resolution with reconciliation instructions – Senate Finance Committee Chairman releases financial derivatives overhaul proposal – IRS official says new financial entities campaign will be broad.

A review of the week's major US international tax-related news. In this edition: US Senate moves toward passage of $1.2 trillion bipartisan infrastructure bill – OECD confirms US government’s intention to abolish Foreign Derived Intangible Income regime.

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.

A review of the week's major US international tax-related news. In this edition: US Senate Majority leader misses initial infrastructure legislation and budget resolution deadlines – IRS addresses cost sharing agreements and inclusion of stock-based compensation costs –  OECD plans to complete work on BEPS 2.0 multilateral convention and model domestic legislation by close of 2021, early 2022.

A review of the week's major US international tax-related news. In this edition: Senate Budget Committee Democrats agree on $3.5 trillion budget resolution, paving way for “human infrastructure” paid for with tax increases – Bipartisan $1 trillion infrastructure negotiators given 21 July deadline – Biden Administration wants global minimum tax in budget reconciliation package; Pillar Two elements on slower track.

A review of the week's major US international tax-related news. In this edition: OECD announces conceptual agreement in BEPS 2.0 project – IRS issues early draft instructions for amended Schedules K-2 and K-3 for 2021 Forms 1065, 1120-S, and 8865.

A review of the week's major US international tax-related news. In this edition: White House, bipartisan senators agree to infrastructure deal – OECD publishes Model Reporting Rules for Digital Platforms: International Exchange Framework.

A review of the week's major US international tax-related news. In this edition: More US Senators publicly support $1.2 trillion bipartisan infrastructure compromise – House passes corporate disclosure package requiring country-by-country tax reporting for multinationals.

A review of the week's major US international tax-related news. In this edition: Bipartisan US Senate group proposes $1.2 trillion infrastructure package – G7 Finance Ministers express strong support for ongoing work on OECD BEPS 2.0 project – Biden Administration’s proposed 15% minimum tax on book earnings could include public disclosure of book-tax differences – IRS announces deferral of applicability date of BEAT qualified derivative payment reporting – Treasury discusses information reporting proposals regarding virtual currencies.

A review of the week's major US international tax-related news. In this edition: US Treasury ‘Green Book’ details Biden Administration’s international tax proposals – President Biden, Senate Republicans continue infrastructure talks – USTR announces and suspends tariffs over digital services taxes – G-7 officials begin meeting; expected to pledge support for BEPS 2.0 talks.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing discusses US international tax proposals – Biden Administration, Senate Republicans trading infrastructure proposals.

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee hearing on infrastructure highlights differences regarding scope and pay-fors – US Treasury proposes 15% global minimum corporate tax rate – IRS official discusses application of US treaties’ derivative benefits test post-Brexit – OECD Multilateral Instrument Conference of the Parties issues interpretative opinion.

A review of the week's major US international tax-related news. In this edition: Biden Administration, Congressional Republicans show some willingness to compromise on infrastructure package – Treasury Green Book detailing President Biden’s tax proposals to be released end of May – House Financial Services Committee reports out CbC financial reporting bill, including taxes – IRS modifies accounting method change guidance related to certain foreign corporations.

A review of the week's major US international tax-related news. In this edition: US Congress, Biden Administration focused on infrastructure plans, proposed tax increases – IRS releases updated early drafts of new Schedules K-2 and K-3, for Forms 1065, 1120-S, and 8865, for 2021 tax year – OECD considering framework for elimination of unilateral DSTs post-BEPS 2.0 agreement – OECD cryptoasset project delayed to 2022.

A review of the week's major US international tax-related news. In this edition: US President Joe Biden addresses joint session of Congress, makes case for multi-trillion dollar American Jobs Plan and American Families Plan – Treasury details plan to direct $80 billion to IRS over next 10 years – PTEP proposed regulations now expected to be released in multiple installments, beginning late summer, early fall 2021 – UN releases third edition of UN Transfer Pricing Manual.

A review of the week's major US international tax-related news. In this edition: President Biden to address joint session of Congress; will pitch infrastructure and American Families Plan proposals – Senate Finance Committee Chairman reintroduces Clean Energy for America Act – UN tax committee approves new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden begins outreach on $2.2 trillion American Jobs Plan – IRS issues proposed regs on foreign investment in Opportunity Zone funds – IRS issues FAQs on International Compliance Assurance Program (ICAP) – EY submits comments on EU Public Consultation on digital levy.

A review of the week's major US international tax-related news. In this edition: US Treasury releases report on Biden Administration’s Made in America Tax Plan – US Senate Finance Committee Chairman releases framework for international taxation – US presents OECD BEPS 2.0 Pillar One proposal to steering group of Inclusive Framework on BEPS – UN Tax Subcommittee releases final draft of new digital taxation article for UN Model Treaty.

A review of the week's major US international tax-related news. In this edition: President Biden unveils $2 trillion infrastructure plan to be paid for with higher CIT rate, international tax changes – US, Japan reach agreement on tax treaty arbitration process – IRS APMA Program releases annual APA update – US Trade Representative proposes 25% punitive tariffs on Austria, India, Italy, Spain, Turkey, and the UK in response to Digital Services Taxes – OECD initiates consultation on commentary to Article 9 (Associated Enterprises) of OECD Model Tax Treaty. .

A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee holds hearing on international taxation – US, 18 other jurisdictions to participate in OECD ICAP – IRS releases practice unit on Section 965 transition tax. .

A review of the week's major US international tax-related news. In this edition: Biden Administration begins to float tax proposals – Senate Finance Committee holds hearings on various aspects of US Tax Code – House, Senate Democrats release international tax bills – IRS official offers international tax guidance update – IRS updates FATCA FAQs.

A review of the week's major US international tax-related news. In this edition: US enacts $1.9 trillion COVID-19 stimulus legislation, including repeal of worldwide interest expense allocation election – IRS Office of Fraud Enforcement initiative to focus on virtual currency – IRS Advance Pricing and Mutual Agreement Program seeing questionable treatment of COVID-related costs – OECD official sees possibility for two simplification measures in BEPS 2.0 Pillar 2 agreement – Platform for Collaboration on Tax issues final version of Toolkit for Tax Treaty Negotiations.

A review of the week's major US international tax-related news. In this edition: US Senate considers $1.9 trillion COVID relief package – US Treasury Secretary takes Pillar 1 safe harbor off table in BEPS 2.0 talks – Murillo named Treasury Deputy Assistant Secretary for International Tax Affairs.

A review of the week's major US international tax-related news. In this edition: US House of Representatives to vote on $1.9 trillion COVID-19 stimulus/relief package on 26 February, action next moves to Senate – US Treasury nominee says goal in BEPS 2.0 talks is to protect US tax revenue and ensure a level playing field.

A review of the week's major US international tax-related news. In this edition: US Congressional tax leader says no consensus on international tax changes – “Platform for Collaboration on Tax” releases toolkit to help developing countries with effective transfer pricing documentation requirements – OECD Forum on Tax Administration releases new handbook for International Compliance Assurance Program (ICAP) – OECD issues 2021 Global Forum Capacity Building Report.

A review of the week's major US international tax-related news. In this edition: US House tax-writing committee approves package representing half of $1.9 trillion COVID relief plan, including international tax provision – Treasury may open project to revive transfer pricing aggregation regulations.

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.

A review of the week's major US international tax-related news. In this edition: New US Treasury Secretary commits to OECD BEPS 2.0 discussions – OECD releases guidance on COVID-19 related tax treaty issues.

A review of the week's major US international tax-related news. In this edition: President Biden inaugurated as US president; Treasury-designate Janet Yellen confirms tax increases to be delayed – US to re-engage in OECD BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: US President-elect Joe Biden announces $1.9 trillion “American Rescue Plan” – Incoming US Senate Finance Committee Chairman Ron Wyden details economic and tax priorities – IRS guidance on Section 864(f) worldwide interest expense allocation a top priority in 2021 – USTR announces investigation findings re Digital Service Taxes in Austria, Spain, and United Kingdom.

A review of the week's major US international tax-related news. In this edition: Democrats control over White House and US Congress has implications for legislation and tax in 2021 – Treasury and IRS release final Section 163(j) business interest expense limitation regulations – US suspends tariff action over Section 301 investigation of France’s Digital Services Tax – OECD Pillar One and Two Blueprint public consultation will be held 14-15 January 2021; Inclusive Framework meeting 27-28 January will be public.

A review of the week's major US international tax-related news. In this edition: Democrats control over White House and US Congress has implications for legislation and tax in 2021 – Treasury and IRS release final Section 163(j) business interest expense limitation regulations – US suspends tariff action over Section 301 investigation of France’s Digital Services Tax – OECD Pillar One and Two Blueprint public consultation will be held 14-15 January 2021; Inclusive Framework meeting 27-28 January will be public.

A review of the week's major US international tax-related news. In this edition: Congress passes $2.3 trillion omnibus spending and coronavirus stimulus legislation with tax extenders; President Trump calls on Congress to pass new bill – OECD issues COVID-19-related transfer pricing guidance.

A review of the week's major US international tax-related news. In this edition: Treasury sends final Section 163(j) interest expense limitation regulations to OMB for review – Treasury notes progress on new tax treaty with Croatia; resumption of US Senate approvals of bilateral tax treaties expected – IRS will continue to prioritize transfer pricing enforcement in examinations, even if adjustment negated by TCJA provisions – Treasury’s FINCEN further extends FBAR filing deadline – OECD BEPS 2.0 Pillar 1 and Pillar 2 comment period ends; BIAC calls for limited BEPS agreement by June 2021 – OECD publishes jurisdiction-specific information on implementation of hard-to-value intangibles approach.

A review of the week's major US international tax-related news. In this edition: IRS APMA Program seeing more COVID-19-related queries regarding APAs – OECD to release COVID-focused TP guidance by end of 2020, beginning 2021 – OECD’s FTA announces piloted International Compliance Assurance Program to become full-fledged program in 2021.

A review of the week's major US international tax-related news. In this edition: OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 Blueprints on 14-15 January 2021 – IRS releases final and proposed PFIC regulations – IRS issues final regulations under Sections 245A and 951A that coordinate two sets of anti-abuse rules – IRS LB&I releases internal guidance re: examinations with Section 965 transition tax issues.

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.

A review of the week's major US international tax-related news. In this edition: Joe Biden projected as winner of US Presidential election; tax policy changes examined – IRS updates listing of CAAs for CbC reports.

A review of the week's major US international tax-related news. In this edition: US elections remain undecided – IRS will not release PTEP proposed regulations by year-end – OECD releases report on taxing virtual currencies.

A review of the week's major US international tax-related news. In this edition: IRS announces plans to limit “telescoping” in APA and MAP cases – IRS turning its attention to enforcement, including international partnerships and cost sharing – IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership.

A review of the week's major US international tax-related news. In this edition: IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR end will not result in deemed taxable exchange – IRS will consider amending existing APAs due to effects of COVID-19 pandemic – US government announces US-Hong Kong shipping agreement will terminate effective 1 January 2021.

A review of the week's major US international tax-related news. In this edition: OECD and Inclusive Framework release series of documents on Pillar 1 and 2 of BEPS 2.0 Project, with new mid-2021 completion – G20 Finance Ministers approve progress and timeline – EU agrees to abide by new OECD Inclusive Framework timeline – UN releases new proposed model treaty article and commentary on taxing digital economy.

A review of the week's major US international tax-related news. In this edition: US government releases final partnership withholding regulations under Section 1446 – IRS announces new compliance campaign targeting NRA’s unreported US rental income – Inclusive Framework holds meeting on final BEPS 2.0 Pillar 1 and 2 blueprints; release expected 12 October 2020.

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.

A review of the week's major US international tax-related news. In this edition: Treasury releases final and proposed regulations on determining CFC status for certain provisions following TCJA repeal of Section 958(b)(4) – Final Treasury regulations under Section 864(c)(8) address US tax consequences of foreign partner's transfer of a partnership interest – OECD will publish final BEPS 2.0 Pillar 1 and 2 blueprints on 12 October 2020.

A review of the week's major US international tax-related news. In this edition: US Congress remains focused on bipartisan negotiations over next coronavirus aid package, extending government funding past 30 September FY-end – Democratic presidential nominee Joe Biden’s campaign releases additional tax proposals – IRS Notice 2020-73 announces one year deferral of certain Section 987 final regulations, related rules – G20/OECD Inclusive Framework on BEPS to meet 8-9 October, agreement on Pillar 1 unlikely.

A review of the week's major US international tax-related news. In this edition: Section 163(j) final regulations to be published in Federal Register on 14 September 2020; would be applicable to tax years starting 13 November 2020 – French Finance Minister accuses US of hindering progress in BEPS 2.0 negotiations.

A review of the week's major US international tax-related news. In this edition: IRS issues final Base Erosion and Anti-abuse Tax (BEAT) regulations – IRS Notice 2020-69 announces plans to issue regulations on application of Sections 951 and 951A to certain S corporations with accumulated E&P – IRS requests comments on collection of information for competent authority requests – OMB OIRA receives final and proposed FTC regulations for review.

A review of the week's major US international tax-related news. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – US, Swiss competent authorities agree to arbitration procedures under tax treaty.

A review of the week's major US international tax-related news. In this edition: US Senate Republicans reportedly planned limited coronavirus aid package not yet released – IRS Large Business and International division gearing up for major increase in refund claims through Form 1120-X as result of coronavirus aid legislation.

A review of the week's major US international tax-related news. In this edition: US Congress begins August recess, no agreement on coronavirus aid legislation – OMB completes review of final rules on DRD limitation for dividends from certain foreign corporations, proposed rules coordinating certain regulations under Section 245A and Section 951A – Draft Schedules K-2 and K-3 for 2021 tax year IRS partnership Form 1065 guided by need to standardize format, officials say.

A review of the week's major US international tax-related news. In this edition: Congress continues talks over another coronavirus bill, no deal reached – Final BEAT regulations now under OIRA review – IRS may refine Tested Unit Rule under GILTI High-Tax Exclusion rules – UN Tax Committee members issue proposal regarding taxation of digital services income.

A review of the week's major US international tax-related news. In this edition: IRS issues highly-anticipated final and proposed Section 163(j) interest limitation regulations and related guidance – IRS will add compliance resources to review stock-based compensation in cost-sharing arrangements.

A review of the week's major US international tax-related news. In this edition: IRS releases final, proposed GILTI regulations on GILTI high exclusion, subpart F high tax exception – IRS official says proposed PTEP regulations coming before year-end – G20 discusses BEPS 2.0, OECD official comments on timeline.

A review of the week's major US international tax-related news. In this edition: IRS releases new draft partnership forms for 2021, Schedule K-2 and K-3 (Form 1065) – Treasury delivers two international tax-related regulatory projects to OMB’s OIRA for review – USTR announces action on France’s Digital Services Tax – OECD expects blueprint proposals for BEPS 2.0 Pillar 1 and 2 by October 2020 – OECD releases new corporate tax statistics, including aggregated CbCR data.

A review of the week's major US international tax-related news. In this edition: US Treasury releases final FDII/GILTI regulations – OMB completes review of final regulations on GILTI high-tax exclusion, proposed rules under Section 954(b)(4) high-taxed subpart F income and Section 964 re: E&P of a foreign corporation – IRS seeing more multilateral APA requests – OECD releases model rules for reporting by platform operators regarding sellers in the sharing and gig economy.

A review of the week's major US international tax-related news. In this edition: US Supreme Court declines to hear Altera cost-sharing case – OECD’s Saint Amans says BEPS 2.0 Pillar 1 talks are ‘still alive’.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: US suspends involvement in OECD BEPS 2.0 Pillar 1 project – OECD issues questionnaire on coronavirus-related transfer pricing compliance concerns – OMB completes review of final Section 250 regulations; Section 163(j), other international projects under review – IRS LB&I provides details on TCJA compliance campaign.

A review of the week's major US international tax-related news. In this edition: Senate Republicans will not take up next coronavirus stimulus package until end of July – IRS seeks recommendations for 2020-2021 guidance projects – USTR releases USMCA regulations.

A review of the week's major US international tax-related news. In this edition: USTR launches investigations of new or proposed Digital Services Taxes in 10 jurisdictions – IRS lists US info exchange agreements re: certain deposit interest paid to residents of those jurisdictions – OECD announces release of Toolkit on the Taxation of Offshore Indirect Transfers.

A review of the week's major US international tax-related news. In this edition: US Treasury sends final FDII, GILTI deduction regulations to OMB for review – OECD official says governments refocusing on BEPS.

A review of the week's major US international tax-related news. In this edition: US government considers incentives to lure manufacturing back to the United States – Treasury announces USMCA to replace NAFTA references in US tax treaties – OECD holds virtual public consultation on 2020 review of CbC reporting.

A review of the week's major US international tax-related news. In this edition: US House set to pass HEROES Act stimulus legislation; Senate will not take up bill – IRS issues final Section 385 debt/equity regulations – IRS modifies MAP, APA filing procedures to reflect COVID-19 pandemic.

A review of the week's major US international tax-related news. In this edition: Congressional Democrats poised to release fourth coronavirus relief package – IRS provides limited DCL and Form 8858 / 8865 relief for temporary activities resulting from coronavirus travel disruptions – OECD postpones July 2020 IF BEPS 2.0 meeting to October.

A review of the week's major US international tax-related news. In this edition: US Congress set to reconvene in May; timing of next COVID-19 stimulus bill uncertain – IRS updates FATCA FAQs, 1 July certification due date extended 15 December 2020.

A review of the week's major US international tax-related news. In this edition: President Trump signs $484 billion interim COVID-19 relief bill into law – IRS issues FAQs on interaction of CARES Act NOL carryback and Section 965 transition tax – IRS releases guidance for foreign businesses and nonresident aliens affected by COVID-19 travel disruptions – IRS issues FAQs on best practices and common mistakes in preparing transfer pricing documentation.

A review of the week's major US international tax-related news. In this edition: IRS grants relief for real estate, farming businesses to withdraw or make late Section 163(j)(7) elections, based on CARES Act – LB&I outlines compliance activities either postponed or allowed through 15 July 2020 – OECD BEPS 2.0 IF Steering Group agrees to continue project on current timelines.

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called ‘Midco’ listed transactions – IRS issues 2019 APA annual report.

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called ‘Midco’ listed transactions – IRS issues 2019 APA annual report.

A review of the week's major US international tax-related news. In this edition: Coronavirus Aid, Relief, and Economic Security Act (CARES Act) has international tax implications for multinationals – IRS issues interim guidance on offers in compromise re: Section 965 transition tax.

A review of the week's major US international tax-related news. In this edition: US Congress enacts $2t Coronavirus Aid, Relief, and Economic Security (CARES) Act stimulus package – IRS posts FAQs on extension of certain filing and payment deadlines to 15 July 2020 – IRS announces FATCA Report (Form 8966) filings due 31 March extended to 15 July 2020 – IRS unveils new People First Initiative to address COVID-19, temporarily suspends key compliance programs.

A review of the week's major US international tax-related news. In this edition: US government responds to COVID-19 pandemic, enacts Families First Coronavirus Response Act – US Senate Republicans release draft $1 trillion COVID-19 bill – US announces tax return filing, payment extensions – IRS issues final foreign tax credit regulations for covered asset acquisitions – OECD to go ‘full steam’ on BEPS 2.0 project – EY’s Global Tax Policy Center releases COVID-19 Stimulus Tracker.

A review of the week's major US international tax-related news. In this edition: IRS expects fewer corporate taxpayer participants in compliance assurance program due to strict eligibility requirements – TIGTA releases report on discrepancy findings that tax withholding required by FIRPTA is not being identified or addressed – Number of TCJA  tax regulations at the OMB's OIRA continues to grow – UK issues 2020 Budget confirming implementation of a 2% DST on revenues earned from 1 April 2020.

A review of the week's major US international tax-related news. In this edition: IRS will not issue regulations aligning transfer pricing rules to TCJA changes re: definition of intangible property before 2021 – House Republicans urge Treasury Secretary to withdraw portion of IRS Notice 2007-55 relating to REIT liquidating distributions – UK government will ‘consider’ US opposition to DST in lead up to trade talks.

A review of the week's major US international tax-related news. In this edition: OMB completes review of final regulations under Sections 245(e) and 267A – G20 endorse BEPS 2.0 “Outline of the Architecture of a Unified Approach on Pillar One” as basis for negotiations.

A review of the week's major US international tax-related news. In this edition: US official says major TCJA international tax guidance on track for release by October 2020; provides unofficial timeline – Altera files writ of certiorari with US Supreme Court in cost sharing case – OECD expected to reach agreement on core BEPS 2.0 Pillar 1 and 2 principles by close of 2020 – OECD issues Consultation Document on “sharing” and “gig” economy.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary confirms US-France DST de-escalation agreement – Treasury Secretary defends TCJA international guidance at congressional hearing – Senate Finance Committee Democrats introduce GILTI amendment – OECD issues final TP report on financial transactions – OECD releases CbCR consultation document – OECD reports BEPS 2.0 Pillar 1 and 2 would raise additional $100b global CIT annually.

A review of the week's major US international tax-related news. In this edition: IRS has no plans to issue additional Section 965 transition tax guidance – IRS will accept PLR requests for determining BEAT base erosion payment – OMB sends final Section 163(j) business interest deduction limitation regulations back to Treasury – Singapore announces US-Singapore TIEA in force 5 March 2020.

A review of the week's major US international tax-related news. In this edition: US supports OECD Pillar 1 proposals as ‘safe harbor’ – IRS rules target's capitalized transaction costs do not create separate and distinct intangible asset – UK leaves EU on 31 January 2020, begins transition period – OECD Inclusive Framework on BEPS meets on Pillar 1 and 2 proposals.

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations for contributions of appreciated property by US persons to partnerships with related foreign partners – IRS’s recently announced Section 965 repatriation relief is case-by-case – US officials comment on pending Section 245A DRD and Section 163(j) interest limitation guidance – US, France trade war over French DST on hold through 2020; France suspends collection of DST.

A review of the week's major US international tax-related news. In this edition: IRS may revise broad definition of interest in pending final Section 163(j) regulations – IRS may amend FMV requirement in proposed regulations for phaseout of LIBOR, variant interest rates – IRS will consider cryptocurrency PLRs – France will not eliminate DST notwithstanding US retaliatory tariffs.

A review of the week's major US international tax-related news. In this edition: USTR holds hearing on tariffs in response to France’s DST – TCJA final regulations on Section 163(j) and hybrid dividends and payments pending OMB review.

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on W/H and reporting tax re US source income paid to foreign persons – IRS proposed regulations modify rules for sourcing income from sales of inventory within/outside US – FinCen further extends FBAR filing deadline – US hopeful pending US tax treaties with Chile, Hungary, and Poland will be approved in 2020 – OECD release additional CbC reporting guidance.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation with CFC look-through provision – IRS issues final Section 871(m) regulations on dividend equivalent payments, extends transition relief – US Treasury sends final Section 163(j) regulations and final Section 267A hybrid mismatch regulations to OMB for review – OECD and US Treasury officials comment on BEPS 2.0 project.

A review of the week's major US international tax-related news. In this edition: OECD holds public consultation on GloBE Pillar 2 proposals – OECD to release economic modeling of Pillar 1 and Pillar 2 proposals in early 2020.

A review of the week's major US international tax-related news. In this edition: IRS releases final BEAT regulations – IRS issues final and proposed FTC regulations – IRS Notice 2019-65 defers applicability date of final Section 987 regulations and related rules by one additional year – US has ‘serious concerns’ over OECD BEPS 2.0 Pillar 1 – USTR proposes punitive duties on French goods over France’s new DST.

A review of the week's major US international tax-related news. In this edition: Participants at OECD public consultation on BEPS Pillar One identify existing global transfer pricing system as needing change – US government holds release of foreign tax credit, BEAT regulations – Spanish Supreme Court rules US RIC entitled to Spanish dividend WHT refund.  

A review of the week's major US international tax-related news. In this edition: IRS issues final regulations on ownership attribution rules for CFC purposes – OMB fall 2019 agenda includes new IRS final reg project on rules for domestic shareholders’ accounting method changes for foreign corporations – OECD holds public consultation on BEPS Pillar One project.

A review of the week's major US international tax-related news. In this edition: Release of IRS foreign tax credit, BEAT regulations imminent – US Treasury officials offer international tax guidance timeline – Ninth Circuit Court of Appeals denies request for en banc rehearing in Altera v. Commissioner – EY submits comment letter on OECD Pillar 1 consultation document. .

A review of the week's major US international tax-related news. In this edition: IRS announces new Section 965 transition tax campaign – IRS warns against using transfer pricing to avoid BEAT – OECD releases Pillar 2 Consultative Document – OECD issues more CbCR guidance – OECD announces new Analytical Database on MNEs and affiliates – OECD releases additional guidance on spontaneous information exchange by no, low-tax jurisdictions.

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 385 regulations removing minimum documentation requirements; announces it will modify “distribution regulations” – OMB completes review of final and proposed FTC regulations – Congressional JCT releases Blue Book explanation for tax legislation enacted in 115th Congress – Draft IRS partnership form and instructions reflect new Section 864(c)(8) – UK receives Brexit extension until 31 January 2020; general election 12 December.

A review of the week's major US international tax-related news. Update on US international guidance at OMB OIRA – IRS to continue scrutiny of virtual currency transactions – IRS concludes Section 952(c) election to include excludible insurance income in subpart F income of CFCs’ US shareholder is obsolete – G20 expresses support for OECD’s two-pillar approach.

A review of the week's major US international tax-related news. US Congress considers spending bill as vehicle for tax extenders, TCJA technical corrections – UK, EU reach agreement on new Brexit deal – OECD hopes to finalize digital tax proposal details in January, political agreement by June 2020.

A review of the week's major US international tax-related news. In this edition: OECD releases Pillar One Consultation Document on digitalization of the economy – IRS Notice 2019-58 addresses final, temporary, and proposed Section 385 debt/equity regulations – IRS issues guidance on tax treatment of cryptocurrency transactions – Foreign tax credit and Section 59A BEAT regulations pending OMB OIRA review.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations on TCJA repeal of Section 958(b)(4) for determining CFC status – IRS releases Rev. Proc. 2019-40 on repeal of Section 958(b)(4); details safe harbors.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry into force of tax protocols with Luxembourg and Switzerland – Bipartisan US Senate lawmakers in early discussions on tax extenders legislation; CFC look-through expires at year-end – European General Court rules Netherlands did not grant illegal State aid to Starbucks – OECD holds first Tax Certainty Day; 2018 MAP statistics released  

A review of the week's major US international tax-related news. In this edition: US Treasury sends final and proposed Section 59A BEAT regulations to OMB for review – IRS reconsidering Form 1120-F nonfilers compliance campaign following TIGTA review – OECD official says Pillar 1 and Pillar 2 proposals will incorporate tax certainty as a core component.

A review of the week's major US international tax-related news. In this edition: US Congress: Update on technical corrections, tax extenders, new tax treaties – International tax-related TCJA fall guidance – Protocol to US-Luxembourg tax treaty enters into force – US, France in talks over Digital Services Tax; US may take action against other nations’ unilateral digital taxes.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry-into-force dates for protocols to US-Japan and US-Span tax treaties.

A review of the week's major US international tax-related news. In this edition: US Treasury announces entry-into-force dates for protocols to US-Japan and US-Span tax treaties.

A review of the week's major US international tax-related news. In this edition: French President comments on new Digital Services Tax – IRS lists jurisdictions with reporting requirements for interest and OID paid to certain NRAs

A review of the week's major US international tax-related news. In this edition: US Ninth Circuit affirms Tax Court’s Amazon transfer pricing decision – IRS will permit domestic partnerships, S corporations to apply rules from proposed GILTI regulations for tax years ending before 22 June 2019 – USTR holds hearing on France’s Digital Services Tax

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.

A review of the week's major US international tax-related news. In this edition: IRS formally withdraws “Altera” CSA memo in light of Ninth Circuit decision – President Trump signs instruments of ratification to tax protocols amending treaties with Luxembourg, Switzerland, Japan, and Spain

A review of the week's major US international tax-related news. In this edition: US threatens retaliation against France’s new DST – IRS begins sending virtual currency letters to taxpayers

A review of the week's major US international tax-related news. In this edition: Altera Corp. files petition for rehearing challenge of 2003 cost sharing regs – IRS publishes final regs relating to the allocation of creditable foreign tax expenditures by a partnership – UK’s Boris Johnson to succeed Theresa May as Prime Minister; UK publishes draft legislation and consultation paper on EU MDR – OECD updates peer review of preferential tax regimes

A review of the week's major US international tax-related news. In this edition: US Senate approves four protocols updating the existing bilateral tax treaties with Luxembourg, Switzerland, Japan and Spain – IRS releases additional information to assist with filing and payment obligations for Section 965 transition tax on untaxed foreign earnings – G7 Finance Ministers support OECD two-pillar project to develop new rules for taxing multinational businesses – 2019 UN tax treaty negotiation manual updated to reflect changes in 2017 UN Model Treaty – APMA’s functional cost diagnostic model intended to help officials with complex cases

A review of the week's major US international tax-related news. In this edition: US government initiates review of France’s new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US government initiates review of France’s new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee reports out 4 tax protocols to full Senate – US Senate Finance Committee leaders urge Treasury to intensify efforts to convince France not to enact DST – IRS official says proposed GILTI regulations’ “high taxed exclusion” prospective date meant to assess election’s operation

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee to vote on protocols to US tax treaties with Switzerland, Luxembourg, Spain, and Japan on 25 June 2019 – US releases final GILTI regulations – IRS temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules – Ninth Circuit reverses US Tax Court in Altera v. Commissioner – US, Cyprus negotiating CA agreement to exchange CbC reports

A review of the week's major US international tax-related news: US Senate may hold long-delayed tax treaty hearing – G20 finance ministers approve OECD’s digital work plan – DC Circuit affirms Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co. SA – Final GILTI regulations due out before 22 June 2019.

A review of the week's major US international tax-related news: OMB completes review of final and proposed GILTI regulations; Treasury to release before 22 June – US participation exemption guidance clears OMB review – IRS issues proposed regulations on exception from tax for foreign pension fund interests in US real property – IRS LB&I withdraws RAB Share Directive for cost sharing arrangements.

A review of the week's major US international tax-related news: OECD releases digital taxation work program – OMB sets December 2019 target date for release of many high-profile international TCJA final regulations – IRS Commissioner says cryptocurrency guidance coming within 30 days – TIGTA issues report on IRS implementation of Section 965 deemed repatriation tax

A review of the week's major US international tax-related news. In this edition: IRS issues final Section 956 regulations – Treasury official confirms final GILTI regulations by 23 June, BEAT regulations this summer – ECOFIN discusses digital taxation.

A review of the week's major US international tax-related news: US Treasury official warns over global DST proposals – New PTI regulations coming before year-end – IRS issues final FX regulations – IRS releases proposed CFC regulations under Sections 954 and 958 – Final GILTI regulations under OMB review – IRS Internal Legal Memo addresses Section 367(d)

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 1446(f) regulations on W/H for non-publicly traded partnerships – Proposed rules on FIRPTA exception for foreign pension funds expected soon – EU comments on IRC Section 250 proposed regulations, criticizes FDII

A review of the week's major US international tax-related news. In this edition: IRS officials say to expect release of proposed Section 1446(f) regulations, final FATCA regulations, and proposed regulations on repeal of Section 958(b)(4) – India ratifies US-India CbC exchange agreement

Description: A review of the week's major US international tax-related news. In this edition: IRS issues revised US Tax Treaty Table 1 – OECD publishes full version of OECD Model Tax Treaty – UN subcommittee releases report on tax challenges of digitalized economy.

A review of the week's major US international tax-related news. In this edition: US officials offer insights on global digital taxation – IRS LB&I launches 3 new international campaigns

A review of the week's major US international tax-related news. In this edition: US House and Senate tax leaders release digital taxation statement – IRS issues correction to final Section 965 transition tax regulations – Immediate action may be required for foreign-owned US disregarded entities – UN issues draft update to transfer pricing manual for developing countries – EU, UK reach agreement on 6-month Brexit delay

A review of the week's major US international tax-related news. In this edition: US House Republican tax writers voice concern to President Trump about France’s DST proposal – US officials comment on future final Section 250 FDII regulations – IRS’s new APMA Functional Cost Diagnostic Model may be used in examinations in ‘appropriate’ cases – GAO issues report on FATCA – OECD Forum on Tax Administration announces ICAP 2.0

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing debates benefits of 2017 TCJA, including international provisions – US, India sign CbC report exchange agreement – IRS releases 2018 APA report – Forum on Tax Administration releases report on tax aspects of sharing and the gig economy at plenary meeting  

A review of the week's major US international tax-related news. In this edition: OECD official offers timeline for global digital taxation project – IRS to release proposed previously taxed income (PTI) regulations in late summer or early fall – IRS issues final FATCA regulations – US-India bilateral agreement for exchange of CbC reports announced – OECD releases beneficial ownership toolkit

A review of the week's major US international tax-related news. In this edition: Final GILTI regulations out before summer, but “round 2” will address loss stock basis adjustment rules – EU comments on US Section 59A BEAT – US Treasury official confident of global consensus on digital allocation of taxing rights – OECD official says immediate goal is to finalize and present digital tax work plan to G-20 Finance Ministers and leaders, OECD technical working parties to follow

A review of the week's major US international tax-related news. In this edition: IRS releases Section 250 proposed regulations on determining deduction for FDII and GILTI – IRS announces hearings on proposed regulations on BEAT, hybrid mismatches – IRS APMA releases Functional Cost Diagnostic Model for APA requests – ITS updates FATCA FAQs – EY submits comments on OECD tax consultation on digitalization of the economy

A review of the week's major US international tax-related news. In this edition: OMB completed review of proposed FDII regulations – US government supports efforts to encourage countries to adopt corporate minimum tax – IRS LB&I memo requires transfer pricing issue teams to consult with APMA – IRS requesting comments on final regulations on imposition of Section 6662 accuracy-related penalty for Section 482 adjustments

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

A review of the week's major US international tax-related news. In this edition: OECD opens public consultation on addressing tax challenges from digitalization of the economy – US Treasury official responds to OECD digitalization proposals – Finalization of US international tax regulations may pass June 2019 deadline

A review of the week's major US international tax-related news. In this edition: US Treasury official responds to OECD policy note on digital taxation – IRS will not relax anti-corporate inversion rules – Code Section 965 final regulations published in Federal Register; clarification on due date for filing transfer agreements

A review of the week's major US international tax-related news. In this edition: OECD issues major Policy Note relating to work on ‘Addressing the Tax Challenges of the Digitalisation of the Economy’ – OECD released Harmful Tax Practices – 2018 Progress Report on Preferential Regimes – US Senate tax leaders voice concern over European DST proposals – Congressional Democrats may use technical corrections as leverage for tax incentives

A review of the week's major US international tax-related news. In this edition: OECD BIAC releases 11 principles to guide tax reform for digital economy – OECD may address more than digital business activity, potentially impacting other IP-intensive business models

A review of the week's major US international tax-related news. In this edition: IRS releases final Section 965 transition tax regulations – US Senate Finance Committee’s first priority is tax extenders legislation

New House Ways and Means Committee Chairman offers hints re: tax agenda – IRS issues final Section 163(j) Form and Instructions

A review of the week's major US international tax-related news. In this edition: US Congress fails to enact year-end tax legislation, Federal government enters into partial shutdown – Outgoing House Ways and Means Committee Chairman releases discussion draft of Tax Technical and Clerical Corrections Act – Status of OMB review of TCJA regulations during government shutdown unclear

A review of the week's major US international tax-related news. In this edition: US House approves tax bill; Senate action unlikely -- Congressional Joint Committee on Taxation releases general explanation of the Tax Cuts and Jobs Act (Blue Book) – IRS issues proposed regulations on Sections 245A(e) and 267A – IRS issues proposed regulations under Section 864(c)(8) on tax treatment of foreign partners gains on sale of a US partnership interest – IRS Notice 2019-01 announces future regulations re: foreign corporations with PTEP -- OMB received proposed Section 250 regulations for review

A review of the week's major US international tax-related news. In this edition: US House tax leader releases modified year-end tax package -- IRS releases proposed Section 59A Base Erosion and Anti-Abuse Tax (BEAT) regulations – IRS issues Section 965 transition tax FAQs -- OMB completes review of proposed TCJA Section 864c()(8) regulations; release imminent – IRS issues proposed FATCA, withholding regulations – US Treasury issues another FBAR extension -- OECD will release major digital tax update end of January 2019

A review of the week's major US international tax-related news. In this edition: US Republican efforts to move tax legislation stall in House – US Treasury sends final Section 965 transition tax regulations, proposed regulations under Section 864(c)(8) to OMB for review – ECOFIN fails to reach agreement on proposed EU Digital Services Tax; US House tax leader weighs in

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on computing interest expense limitation under Code Section 163(j) – IRS releases complex foreign tax credit regulations – Congressional Republicans advance year-end tax legislation in lame-duck session

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: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance – US House tax leader eying 70-80 TCJA technical corrections for lame-duck legislation

A review of the week's major US international tax-related news. In this edition: US mid-term election will affect tax in Congressional lame-duck and 2019 – Treasury sends TCJA’s BEAT and FTC proposed regulations to OMB for review -- EU Ministers meet on proposed Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS recently issued Section 163(j) draft Form 8990, draft instructions for BEAT Form 8991 – IRS LB&I issues 3 more international tax compliance campaigns -- US House tax leader issues warning about proposed UK DST, other unilateral measures – Netherlands announces intent to repeal Decree re: US-Netherlands tax treaty relation to hybrid entities

A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existing tax treaty

A review of the week's major US international tax-related news. In this edition: Proposed FTC and Section 163(j) regulations release to OMB Office of Regulatory Affairs imminent -- Proposed PTI regulations unlikely to be released as complete package by year-end – 2018 IRS deadline for QI, Withholding Foreign Partnership and Withholding Foreign Trust applications is 16 November 2018 – OECD making progress on digital tax framework

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA’s FDII later this month -- US official says OECD making good progress on long-term digital tax package

A review of the week's major US international tax-related news. In this edition: IRS Notice 2018-78 provides welcome amendments to Section 965 proposed regulations – IRS proposed regulations on GILTI to be published in Federal Register on 10 October 2018; 60-day comment period begins

A review of the week's major US international tax-related news. In this edition: US House moves forward with ‘tax reform 2.0’ – GILTI regulations to be finalized by June 2019 – IRS restructuring Advance Pricing and Mutual Agreement program.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations removing IRC Section 385 debt/equity documentation regulations – IRS releases draft Form 8991 on new Section 59A BEAT provision -- IRS Notice 2018-72 delays effective date of Section 871(m) dividend equivalent payments by two years – US House tax leader urges IRS to issue virtual currency guidance – OECD issues additional CbCR guidance.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 951A GILTI regulations – IRS issues guidance on REIT Section 951A, foreign currency income inclusions – House tax writing committee approves Tax Reform 2.0

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-election session – House tax-writing committee to move Tax Reform 2.0 week of 10 September

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: US Treasury sends TCJA’s global intangible low taxed income (GILTI) regulations to OMB for review – IRS issues draft forms for GILTI, foreign derived intangible income (FDII) provisions

A review of the week's major US international tax-related news. In this edition: Second Circuit Court of Appeals affirms district court decision in Trusted Media Brands, Inc. v. USA -- Eighth Circuit Court of Appeals vacates 2017 Tax Court order in Medtronic, Inc. v. Comm’r

A review of the week's major US international tax-related news. In this edition:US Ninth Circuit withdraws opinion in Altera – US Tax Court rules partnership’s Section 1446 withholding tax liability is a partnership item – Congressional Republicans urge President Trump to nominate OECD ambassador

IRS releases Section 965 proposed regulations on TCJA repatriation transition tax -- Ninth Circuit reverses Tax Court in Altera cost sharing case – DC Circuit overturns Tax Court in Good Fortune Shipping, rules Section 883 ‘”bearer share” regulations invalid -- IRS FATCA certification portal is now live

A review of the week's major US international tax-related news. In this edition: US House tax leader releases Tax Reform 2.0 framework – OMB completes review of Proposed Section 965 transition regulations – OECD Secretary-General Report to G20 Finance Ministers and Central Bank Governors on BEPS, tax transparency released

A review of the week's major US international tax-related news. In this edition: US House Republicans to release outline of proposals for “phrase 2” tax reform bill week of 23 July 2018 – OMB review of proposed Section 965 repatriation transition regulations pending -- Treasury official offers insights into coming TCJA international tax guidance – IRS official say countries reviewing how to use CbC reporting data

A review of the week's major US international tax-related news. In this edition: US international-focused tax technical corrections bill expected following November elections – Tax Reform 2.0 may fine-tune new international provisions – IRS issues final anti-corporate inversion regulations – IRS LB&I announces two new compliance campaigns on repatriation of foreign earnings -- IRS LB&I issues transfer pricing, automatic exchange of information memos – US Treasury Inspector General for Tax Administration releases negative FATCA report – OECD issues discussion draft on financial transactions under BEPS Actions 8-10

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee Chairman Kevin Brady discusses tax reform 2.0 – IRS to issue new proposed rules this year for controlled foreign corporations’ previously taxed income – proposed regulations withdrawing the Section 385 debt-equity documentation rules officially “pending review” – OECD Multilateral Convention to enter into force on 1 July 2018 – OECD announces publication of stakeholder comments it received in response to request for public comments on revisions to OECD Transfer Pricing Guidelines – OECD launches comparable tax revenue database

A review of the week's major US international tax-related news. In this edition:US Supreme Court rules in South Dakota v. Wayfair; major impact on all companies with sales to US, including foreign-based companies – US House Budget Committee approves FY 2019 budget resolution -- OECD releases two reports, on Hard-to-Value Intangibles and application of Transactional Profit Split Method

A review of the week's major US international tax-related news. In this edition: US congressional tax leader wants ‘phase 2’ reform bill released before August recess – IRS announces plan to delay application of Section 987 FX regulations for additional year -- IRS will give US W/H agents 60 days following issuance of IDR to cure accounts – IRS soon to release final FATCA regulations for FFI ‘sponsors’ – IRS will issue two sets of guidance for TCJA’s new Section 1446(f)

A review of the week's major US international tax-related news. In this edition: IRS announces Section 965 transition late-payment penalty and filing relief -- US officials offer more insights on upcoming international TCJA guidance – US taxpayers with high-risk transfer pricing and PE issues that participate in OECD’s ICAP may face IRS exam – IRS to deploy portal for FATCA certifications by late July, early August

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.

A review of the week's major US international tax-related news. In this edition: US House Republicans, Trump Administration discussing framework for ‘phase two’ tax reform -- Final anti-corporate inversion regulations may be out in June -- IRS LB&I reviewing ongoing compliance campaigns in light of TCJA -- Updated UN Model Tax Treaty released.

A review of the week's major US international tax-related news. In this edition: Acting IRS Commissioner talks at May 2018 ABA Section of Taxation meeting about guidance projects implementing the TCJA – Treasury and IRS officials also address several tax reform related issues at the Meeting – IRS official reports IRS considering whether potential regulations under Section 267A should prevent the denial of deductions when a hybrid instrument or entity is not the cause of preferential treatment of relevant income – US District Court dismisses taxpayer’s suit against IRS in transfer pricing dispute.

A review of the week's major US international tax-related news. In this edition: US OMB Office of Regulatory Affairs provides insight into scope and release of TCJA international tax regulations – US House Ways and Means Committee to hold hearings on economic effects of tax reform – IRS announces plans to issue regulations expanding exception to Section 956(c) US property -- OECD considering revising Transfer Pricing Guidelines.

A review of the week's major US international tax-related news. In this edition: US House tax chairman floats “Tax Reform 2.0” – TCJA Technical Corrections unlikely in 2018 – IRS comments on interpreting new Section 163(j) -- OECD may up release consensus blueprint on digital economy to 2019.

A review of the week's major US international tax-related news. In this edition: Treasury and IRS officials offer TCJA international tax insights -- Final FATCA regulations close to release – Tax professor to advise on OMB/Treasury tax regulation agreement – US, Indonesia release MOU on CbC reporting – US and Costa Rica sign new TIEA.

A review of the week's major US international tax-related news. In this edition: European Union continues deliberations on elements of US tax reform – OECD Tax Director comments on US tax reform

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-27 -- IRS Notice 2018-28 provides details on Section 163(j) business interest expense limitation – IRS Notice 2018-29 provides interim guidance for dispositions by non-US persons of interests in non-PTPs -- IRS Notice 2018-31 offers guidance on changes to the CbC reporting for US MNCs considered national security contractors -- IRS issues 2017 APA report – OECD has begun review of US tax reform.

A review of the week's major US international tax-related news. In this edition:US takes issue with EU digital tax proposals – EU to consider putting US on tax haven blacklist – US IRS issues FATCA publications

A review of the week's major US international tax-related news. In this edition:EU, OECD address digital taxation -- US strongly opposes taxes on digital economy – IRS to issue consolidated group guidance re: new Sections 965 and 163(j) in early April – IRS considering GILTI in context of US foreign tax credit regime – OECD releases new report on PE attribution of profits – OECD MLI will enter into force 1 July 2018

A review of the week's major US international tax-related news. In this edition: Congressional Republicans, Trump Administration mull “phase 2” tax reform – Joint Committee on Taxation working on tax reform “bluebook,” identifying technical corrections – IRS released FAQs on Section 965 repatriation transition tax – Final anti-corporate inversion regulations completed -- OECD released Interim Report on tax challenges from digitalization.

A review of the week's major US international tax-related news. In this edition: IRS expands “no TIN” list to include foreign jurisdictions that offer TINS; Australia added to list – Treasury considering carving-out long-term bank loans from “cash or cash equivalents” in Section 965 transition tax -- EU requests OECD Forum on Harmful Tax Practices conduct “fast track” review of certain US tax reform provisions.

A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee Chairman expects series of small, technical corrections bills to TCJA -- House Ways and Means Tax Policy Subcommittee will hold hearing on tax extenders on 14 March – Senior Treasury tax official resigns.

A review of the week's major US international tax-related news. In this edition: US Treasury officials offer updates on TCJA international guidance -- IRS LB&I issued guidelines for delinquent Forms 1120-F, waiver requests – EU surveying European multinationals re: US tax reform.

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

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

A review of the week's major US international tax-related news. In this edition: US Treasury addresses tax guidance for TCJA – Joint Committee on Taxation reviewing issues for TCJA technical corrections, but no date – ‘Off-year’ Blue Book on TCJA possible.

A review of the week's major US international tax-related news. In this edition:IRS issues more repatriation transition guidance in Notice 2018-13 – Treasury close to determining fate of Section 385 debt/equity regulations -- Treasury Secretary attempts to ease European concerns regarding US tax reform legislation.

A review of the week's major US international tax-related news. In this edition: US technical tax corrections bill on hold for now – IRS LB&I issues series of internal transfer pricing directives – IRS says taxpayers can elect mark-to-market method of accounting in recent Section 988 proposed regulations.

A review of the week's major US international tax-related news. In this edition: US Treasury grants further extension for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2018-07 on new transition tax – IRS suspends W/H obligations under new Section 1446(f) for certain publicly traded partnership interests – FASB to issue additional guidance on ASC 740, Income Taxes, re: provisions in Tax Cuts and Jobs Act -- US Tax Court rules 6-year limitations period in Section 6501 only applies for tax years to which Section 6038D foreign financial asset reporting requirement effective.

A review of the week's major US international tax-related news. In this edition: US tax reform has tax accounting implications; SEC offers financial statement reporting relief – EU voices concern over US tax reform’s international provisions.

A review of the week's major US international tax-related news. In this edition: US Congress passes landmark tax reform legislation, President Trump signs bill into law – House Republican tax leader says more US tax legislation coming – IRS issues proposed FX regulations – US, Spain sign CAA to exchange CbC Reports – IRS to appeal Grecian Magnesite Mining to DC Circuit Court of Appeals.

A review of the week's major US international tax-related news. In this edition: US tax reform bill finalized; Congress to vote week of 18 December -- US, France sign joint statement on exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House, Senate vote to go to conference committee to reconcile final tax reform bill – Transition period floated for tax reform international provisions – Repeal of ACA mandate may be included in final tax reform bill – Treasury official expects considerable “sub-regulatory guidance” after enactment of tax reform.

A review of the week's major US international tax-related news. In this edition: US Senate poised to pass US tax reform bill -- IRS may not complete bilateral CAAs by year-end for exchange of CbC reports -- IRS issues proposed regulations on international issues related to new partnership audit regime -- IRS rules GRA term fixed as of date of initial transfer -- US to appeal IRS violated APA regarding anti-inversion regulations.

A review of the week's major US international tax-related news. In this edition: US Senate to consider Finance Committee tax reform bill after Thanksgiving holiday – Congressional Republicans, Trump Administration officials aim to enact tax reform by year-end.

A review of the week's major US international tax-related news. In this edition:US House of Representatives approves comprehensive tax reform bill – US Senate Finance Committee reports out tax bill; consideration on Senate floor expected week of 27 November.

A review of the week's major US international tax-related news. In this edition:Congress moving forward on competing tax reform bills; action expected -- IRS announces 3 new international tax compliance campaigns -- OECD published updated Transfer Pricing Country Profiles.

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee releases comprehensive tax reform bill -- Treasury considering clarifications to ’F’ reorganization regulations -- US official suggests non-delta-one transaction rules in Section 871(m) dividend equivalent regulations may not take effect.

A review of the week's major US international tax-related news. In this edition:House approves Senate-passed FY 2018 budget resolution; Ways and Means Committee tax reform bill set for release 1 November, legislative markup to begin 6 November – Treasury official says Section 385 debt/equity regulations ‘overly burdensome’ and will be substantially amended – David Kautter, current Treasury Assistant Secretary for Tax Policy, also named Acting IRS Commissioner.

A review of the week's major US international tax-related news. In this edition: US Senate approves FY 2017 budget resolution with tax reform reconciliation instructions – Treasury Secretary, House Speaker expect tax reform in 2017 – Administration official says tax reform details negotiable, except 20% CIT rate and middle-class relief

A review of the week's major US international tax-related news. In this edition:US House Republicans remain committed to enacting tax reform in 2017 – Foreign minimum tax may be necessary to adopt US territorial tax system – Bipartisan group of House tax writers call for partial withdrawal of FIRPTA Notice 2007-55

A review of the week's major US international tax-related news. In this edition:US House and Senate Republicans move forward on reconciliation instructions for passage of US tax reform -- Senate Finance Committee holds hearing on international tax reform – US Treasury issues report on 8 tax regulations identified as burdensome, including debt/equity and FX regulations – IRS Notice 2017-57 announces deferral of applicability date of final Section 987 FX regulations.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans release tax reform framework -- IRS issues draft update of APA template – OECD releases first peer review reports on minimum standards on Action 14, improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Senate Budget Committee agrees on FY ’18 Budget Resolution; implications for tax reform – “Big 6” tax reform consensus document released next week – US Treasury to publicly release report on “significant tax regulations” in September – IRS official upbeat on countries’ implementation of OECD dispute resolution recommendations; concern over established transfer pricing principles.

A review of the week's major US international tax-related news. In this edition: US Tax Reform “consensus document” set for release week of 25 September – President Trump pushes for 15% CIT rate – Treasury/IRS Guidance Plan to be released in fall – Deadline for Treasury to report recommendations on “significant tax regulations” 18 September.

A review of the week's major US international tax-related news. In this edition: Congress approves bill to provide hurricane relief funding – President Trump calls for Democrats to join him in support of an “American Model” of tax reform – OECD releases further guidance on CbC Reporting – Lafayette G. "Chip" Harter III appointed deputy assistant secretary for international tax affairs for the US Treasury

A review of the week's major US international tax-related news. In this edition: Renewed push for US tax reform after Labor Day – Trump Administration expects Congress to take lead on reform legislation.

A review of the week's major US international tax-related news. In this edition: Trump Administration, Congressional Republicans to release details on tax reform in “short order” – “Big 6” negotiators looking for revenue for tax reform.

A review of the week's major US international tax-related news. In this edition: White House tax negotiators and congressional leaders plan to release document outlining framework for tax reform -- Congressional tax staffers to focus on anti-base erosion rules now that proposed border adjustment tax will not be adopted.

A review of the week's major US international tax-related news. In this edition: US corporate tax rate may settle in low to mid-20% range – IRS extends transition period for applying parts of Section 871(m) rules – IRS now accepting Form 8975, Country-by-Country Report and Schedules A.

A review of the week's major US international tax-related news. In this edition: Trump Administration outlines new strategy for enacting US tax reform – Kautter confirmed as new Treasury Assistant Secretary (Tax Policy) -- Tax Court holds US parent's CFCs held US property under Section 956 as result of intercompany transactions -- Tax Court rules IRS abused its discretion in cancelling two APAs – US concludes Competent Authority Arrangements for exchange of CbC reports with Australia and Estonia.

A review of the week's major US international tax-related news. In this edition: House border adjustability proposal no longer under consideration for US tax reform – Few repeal recommendations expected in final report on 8-Obama-era tax regulations deemed significant -- US signs 5 more Competent Authority Arrangements for automatic exchange of CbC reports.

A review of the week's major US international tax-related news. In this edition: US House Budget Committee approves FY 2018 budget resolution with reconciliation instructions for US tax reform – White House official says “Big 6” and their staffs making headway on US tax reform – US Senate Finance Committee advances nomination of David Kautter for Treasury Assistant Secretary for Tax Policy -- US Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments; broad implications and possible refund claims -- Deadline approaching for certain MNCs to request suspension of MAP-related deadline under Mexico-US income tax treaty – OECD released updated version of Guidance on the Implementation of Country-by-Country Reporting.

A review of the week's major US international tax-related news. In this edition: Trump Administration wants draft tax reform plan “locked in place” before Congress’ August recess – Senate Finance Committee and House Ways and Means Tax Policy Subcommittee to hold tax reform hearings next week -- OECD released draft contents of next update to OECD Model Tax Convention.

A review of the week's major US international tax-related news. In this edition: Robert Stack addresses prospect of territorial tax system at University of Oxford tax conference – Chairman Brady and Speaker of the House Ryan to possibly continue advocating for border adjustment tax – President Trump's nominee for Treasury assistant secretary for tax policy David Kautter moves forward – US IRS announces launch of CbC reporting on website with MNE implications.

A review of the week's major US international tax-related news. In this editio enate Finance Committee turns to US tax reform -- IRS finalizes Form 8975, Schedule A, Instructions for CbC Reporting – OECD to release new TP Guidelines, final report on branch mismatch structures, and MLI database.

A review of the week's major US international tax-related news. In this edition: US House Speaker calls for comprehensive, permanent tax reform in 2017 – IRS has signed 12 CA agreements for CbCR exchange – OECD releases discussion drafts on PE profit attributions, revised guidance on profit splits – OECD announces TP toolkit for developing nations lacking data.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman proposes 5-year border adjustability phase-in period – IRS considering ways to simplify FTIN process – IRS reconsidering transfer pricing case selection – US, Canada sign CbC competent authority agreement.

A review of the week's major US international tax-related news. In this edition: Trump Administration preparing detailed tax reform plan for Congress – US signed five competent authority agreements for exchanging CbC reports – US considering agreeing to and publicizing transfer pricing safe harbor rules – 68 jurisdictions signed Multilateral Instrument.

A review of the week's major US international tax-related news. In this edition: US Treasury Secretary pressed on how to pay for tax reform – Congressional supporters of border adjustability proposal not giving up – OMB Director says Administration does not necessarily support deficit neutral tax reform.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means tax reform hearing focuses on border adjustability -- Senate Majority Leader expresses optimism for US tax reform -- Trump Administration releases $4.094 trillion FY 2018 Budget blueprint.

A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee held first hearing on tax reform in new Congress – W&M hearing on border adjustability proposal scheduled for 23 May – Trump Administration to release FY’18 Budget on 23 May -- US Treasury has begun review of final, temporary and proposed tax regulations issued after 1 January 2016 – Treasury moving tax regulations consistent with ‘freeze’ order -- US in tax treaty discussions with Ireland, Luxembourg, Netherlands, Argentina and Colombia.

A review of the week's major US international tax-related news. In this edition: Trump Administration officials discuss tax reform with Republican Senate Finance members – President Trump comments on border adjustability, suggests 10% repatriation rate – House Ways and Means Committee to hold tax reform hearing on 18 May – Trump Administration nominates Dave Kautter as Treasury Assistant Secretary for Tax Policy.

A review of the week's major US international tax-related news. In this edition: President Trump says Administration’s tax reform plan is open to negotiation – House Republican goal now to develop single tax reform proposal palatable to both Administration and Congress – US Treasury making progress in negotiating competent authority agreements to exchange CbC reports -- OECD released update on exchange relationships for exchanging CbC reports.

A review of the week's major US international tax-related news. In this edition: Trump Administration releases tax reform plan -- President Trump signs Executive Order to review significant tax regulations issued since 1 January 2016 – US Tax Court rules modification of variable prepaid forward contracts does not trigger gain realization – IRS files notice of appeal in Medtronic transfer pricing case.

A review of the week's major US international tax-related news. In this edition: Trump Administration confirms tax reform in 2017 – White House to release tax reform plan “very soon” – Treasury may resume issuing tax regulations – President to sign Executive Order to review significant tax regulations issued in 2016.

A review of the week's major US international tax-related news. In this edition: Trump Administration to return to ACA repeal, then tax reform.

A review of the week's major US international tax-related news. In this edition: US tax reform, another health care deal dominated discussions before Congressional recess – IRS extended deadline for submitting QI, foreign withholding partnership, and foreign withholding trust agreement renewal requests -- IRS APMA issued 18th annual Advance Pricing Agreement report –- OECD released updated guidance on Country-by-Country Reporting.

A review of the week's major US international tax-related news. In this edition: President Trump and Congressional Republicans pivot to tax reform following ACA repeal failure – UK triggers Brexit; sets stage for complex negotiations with EU.

A review of the week's major US international tax-related news. In this edition: TUS House Ways and Means Committee Chairman expects Blueprint’s border adjustability proposal will be included in US tax reform; but with phase-in and modifications – IRS to resume issuing “sub-regulatory” guidance – US Tax Court rules for Amazon.com, Inc., in transfer pricing cost sharing case – Country-by-Country Reporting update.

A review of the week's major US international tax-related news. In this edition: Tax reform takes backseat as Congress focuses on health care reform – Senate Majority Leader less optimistic for completing tax reform by August recess – Treasury official expects government to resume issuing tax guidance sooner, rather than later.

A review of the week's major US international tax-related news. In this edition: President Trump delivers address to Congress; US tax reform remains a priority – IRS issues draft instructions for new Form 8975, Country by Country Report, and accompanying Schedule A, Tax Jurisdiction and Constituent Entity Information.

A review of the week's major US international tax-related news. In this edition: ECOFIN agrees on amendments to the Directive addressing hybrid mismatches involving non-EU countries - Trump Administration expects to release Affordable Care Act replacement soon – Lawmakers and the business community continue to discuss border adjustment tax.

A review of the week's major US international tax-related news. In this edition: President Trump holds meeting with CEOs of major retailers to discuss tax reform and border-adjustable tax proposal – Congressman Mike Kelly calls for a more methodical approach in trying to pass tax reform legislation to impose a border-adjustable tax – IRS official at recent International Tax Institute luncheon notes proposed Section 901(m) regulations include broader language than the original statute because they are meant to act as a catchall for transactions not targeted by Section 901(m) – IRS official at recent New York conference indicates the IRS will not be releasing any guidance other than most routine ones in the near future; practitioners caution that consolidated group members should ensure that they satisfy the Section 385 debt-equity documentation requirements – Steven Mnuchin sworn in as 77th US Treasury secretary.

A review of the week's major US international tax-related news. In this edition: President Trump to release comprehensive tax reform plan in coming weeks -- Japan confirms US limited partnership is fiscally transparent for Japanese tax purposes when applying US-Japan treaty.

A review of the week's major US international tax-related news. In this edition: US Senate will conduct its own tax reform process, not simply accept House bill -- IRS LB&I releases new compliance initiatives, including 3 international tax areas.

A review of the week's major US international tax-related news. In this edition: Donald Trump assumes the US presidency; comprehensive tax reform a priority – Final anti-corporate inversion regulations released – IRS issues temporary regulations denying nonrecognition treatment for contributions of appreciated property to partnerships with foreign partners – IRS issues final dividend equivalent rules – IRS Rev. Proc. 2017-23 provides details on CbC voluntary reporting.

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: Tax reform and Obamacare repeal top Republican agenda as Congress returns to Washington – IRS releases extensive FATCA-related guidance.

A review of the week's major US international tax-related news. In this edition: Congress returns for 115th Congress and US tax reform debate – IRS issues final PFIC regulations – US, Argentina sign Tax Information Exchange Agreement.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says Republican tax reform plan will include border adjustability – Upcoming IRS LB&I audit campaign will include both inbound and outbound international tax issues -- Pending cross-border partnership transfer regulations will be effective for transfers occurring on or after 6 August 2015 – IRS Notice 2017-07 modifies effective date of deferral rules of Reg. Section 1.987-12(T).

A review of the week's major US international tax-related news. In this edition: Congressional Republican leaders offer insights into plans for US tax reform – IRS issues final regulations under Section 367 – Final Section 6038A regulations released.

A review of the week's major US international tax-related news. In this edition: Congress ends lame-duck session without Tax Technical Corrections – IRS issues Section 901(m) regulations limiting creditability of foreign taxes following covered asset acquisitions – IRS releases long-awaited regulations under Section 987 – IRS posted draft Form 8975, Country-by-Country Report, on IRS website.

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.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans bullish on prospects for US tax reform in 2017 – IRS to issue FATCA regulations package soon.

A review of the week's major US international tax-related news. In this edition: Congress returns for lame-duck session following elections – Chances for comprehensive US tax reform improve – Treasury officials offer update on pending international guidance – Treasury looking at method for investment funds to prove US beneficial ownership for tax treaty purposes.

A review of the week's major US international tax-related news. In this edition: US election increases chances of comprehensive tax reform in 2017.

A review of the week's major US international tax-related news. In this edition: IRS issues package of Subpart F regulations – US to share summaries of unilateral APAs with foreign governments, following OECD BEPS recommendations.

A review of the week's major US international tax-related news. In this edition: US officials offer more insights into recent Section 385 debt/equity regulations – New FATCA Form W-8BEN-E required beginning 1 January 2017 -- Regulation package on Section 871(m) dividend equivalent payments and withholding rules coming, but not before mid-November.

A review of the week's major US international tax-related news. In this edition: Final and Temporary Section 385 debt/equity regulations significantly narrow scope of earlier proposed rules – US officials offer insights on Section 385 regulations – US government to focus on cross-border intangible property transfers for partnerships and corporations -- US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation if requirements met – OECD announces establishment of automatic info exchange relationships, global review of MAP programs.

A review of the week's major US international tax-related news. In this edition: Obama Administration issues final and temporary debt/equity regulations under IRC Section 385 – OECD held public consultations on two discussion drafts: Additional Guidance on Profit Attribution to PEs and Revised Guidance on Profit Splits.

A review of the week's major US international tax-related news. In this edition: Final Section 385 debt/equity regulations sent to White House Office of Information and Regulatory Affairs for review -- House Ways and Means Committee Republicans again urge Administration to delay finalizing Section 385 regulations – US Treasury official strongly criticizes EU State aid investigations – EY global survey finds increasing audits and more aggressive enforcement from tax authorities around the world.

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: US government reaction to EU State aid investigations – House speaker expects tax reform in 2017 – IRS official predicts avalanche of MAP cases.

A review of the week's major US international tax-related news. In this edition: Congress returns from summer recess to short pre-election session – Treasury Secretary to meet with House Ways and Means Committee members on Prop. Section 385 debt/equity regulations – IRS issues Rev. Proc. 2016-46 providing foreign insurance guidance.

A review of the week's major US international tax-related news. In this edition: European Commission finds Ireland granted illegal State aid and orders recovery – US, Canada informally discussing joint audits – Congress returns to session after Labor Day.

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: US Treasury and IRS issued 2016-2017 Priority Guidance plan – IRC Section 5000(c) final regulations released on 2-percent excise tax on US government payments to foreign persons -- Treasury official confirms Administration can address unintended consequences in Proposed Section 385 debt/equity regulations.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Chairman comments on lawsuit against anti-corporate inversion regulations – US presidential candidates talk tax plans – ABA Section of Taxation submits comments on cloud computing.

A review of the week's major US international tax-related news. In this edition: US Treasury official says no set deadline for finalization of Section 385 debt/equity regulations – US, Singapore announce plans for reciprocal FATCA IGA with automatic info exchange, TIEA -- IRS announces IGAs not in force on 1 January 2017 will not be treated as in effect – US Chamber of Commerce files lawsuit challenging validity of anti-corporate inversion regulations.

A review of the week's major US international tax-related news. In this edition: Democrats hold National Convention in Philadelphia – IRS posts revised version chief counsel notice CC-2016-009 – Treasury and IRS officials discuss final CbC reporting regulations at July luncheon in Washington – Top officials at OECD tax policy symposium note that consistent implementation of the OECD’s recommendations is key to reducing tax uncertainty – European Commission would like to see tougher standards for determining which territories should be on the tax haven blacklist.

A review of the week's major US international tax-related news. In this edition: Congress to reconvene after Labor Day – Treasury and IRS hope to finish guidance projects before Obama administration ends – Treasury Deputy Assistant Secretary (International Tax Affairs) Robert Stack notes there are four main areas where Section 385 regulations could have unintended results-- Andrew Hickman former head of the OECD’s transfer pricing group, speaks at National Association for Business Economics Transfer Pricing Symposium in Washington.

A review of the week's major US international tax-related news. In this edition: IRS holds hearing on Proposed Section 385 debt/equity regulations -- OECD to present criteria to identify uncooperative jurisdictions for tax transparency purposes – Multilateral instrument to be opened for signature by end of 2016 -- Additional OECD BEPS discussion drafts coming.

A review of the EPS 's major US international tax-related news. In this edition: Treasury officials brief members of Congress on Proposed Section 385 debt/equity regulations – IRS issues proposed Qualified Intermediary Agreement – OECD releases BEPS documents for public comment.

A review of the week's major US international tax-related news. In this edition: US releases final country-by-country (CbC) reporting regulations – House W&M Republicans request comment period extension for Proposed Section 385 debt/equity regulations; Treasury remains firm – House tax reform blueprint details to be filled in; House Democrats take aim – OECD releases more guidance on CbC reporting.

A review of the week's major US international tax-related news. In this edition: House Tax reform blueprint released -- Treasury and IRS set 14 July hearing on Proposed Section 385 debt/equity regulations – House Ways and Means Democrats comment on Proposed Section 385 regulations -- US, Luxembourg announce plans to modify triangular provision in tax treaty -- UK votes for Brexit; major consequences including in regard to taxation.

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A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Democrats to target corporate inversions – US, EU continue dispute over EU state aid investigations – G-20 to promote tax certainty in wake of BEPS project -- Treasury ponders further changes to Proposed Section 385 debt/equity regulations – US Tax Court holds for taxpayer in nearly $1.36 billion transfer pricing case.

A review of the week's major US international tax-related news. In this edition: US House tax reform blueprint will cover international, business and individual reform – Treasury not inclined to delay finalization of Prop. Section 385 debt/equity regulations – Treasury will offer optional CbC reporting for 2016 -- Temporary and proposed withholding regs implementing IRS Notice 2015-10 expected soon – OECD draft requests input on multilateral instrument.

A review of the week's major US international tax-related news. In this edition: House tax leader says proposed Section 385 debt/equity regulations punitive and make US less competitive – Upcoming House tax reform blueprint will include framework for international tax reform – House Ways and Means members fine-tuning innovation box proposal -- Senate Finance Committee holds second hearing on corporate integration – Bipartisan Senate tax leaders again urge Administration to take action on EU state aid investigations – ECOFIN agrees to general approach regarding EU Anti-Tax Avoidance Directive.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee holds corporate integration hearing – Sen. Wyden releases comprehensive derivatives taxation draft – House Ways and Means Tax Policy Subcommittee Chair says US international reform remains a priority -- Treasury Secretary Jack Lew called on Congress to allow reciprocal exchange of information under FATCA.

A review of the week's major US international tax-related news. In this edition: A review of the week's major US international tax-related news. In this edition: Proposed Section 385 regulations a primary focus at recent ABA Section of Taxation meeting and PLI conference – Recent US model treaty also a topic at ABA meeting – House Ways and Means Tax Policy Subcommittee holds hearing to discuss ideas for broader tax reform – Senate Finance Committee Chairman Orrin Hatch to hold hearing to discuss corporate integration.

A review of the week's major US international tax-related news. In this edition: US Treasury official calls for more MNC involvement in global international tax debate – New IRS regulations propose to treat certain foreign-owned domestic disregarded entities as separate from their owners for Section 6038A purposes -- US government looking for comments on cash pooling arrangements in Section 385 regulations context.

A review of the week's major US international tax-related news. In this edition:House comprehensive tax reform blueprint to be released end of June – Senate Finance holds business tax reform hearing – Treasury still considering whether to expand limits to post-inversion planning beyond inverter companies – US government to allow optional CbC reporting for 2016 to resolve gap year issue -- New IRS Associate Chief Counsel (international) lists top international guidance priorities – IRS notice with new draft 2017 qualified intermediary agreement coming.

A review of the week's major US international tax-related news. In this edition:Direction of US House international tax reform draft uncertain – Senate Finance Committee Chairman calls for comprehensive tax reform to curb corporate inversions – Senate corporate integration proposal will be revenue neutral -- New US anti-inversion rules, debt equity regulations may not be finalized at same time.

A review of the week's major US international tax-related news. In this edition: European Commission proposes Directive for public CbC reporting of tax information – Top EU official discusses State Aid investigations with US officials -- Draft Finance Committee corporate integration plan may include nonrefundable 35% withholding tax on interest payments and dividends – House and Senate introduce identical technical corrections bills – IRS proposed regulations address Section 305(c) deemed distributions and related withholding.

A review of the week's major US international tax-related news. In this edition: US government issues anti-corporate inversion regulations – Treasury and IRS release far-reaching proposed earnings-stripping rules.

A review of the week's major US international tax-related news. In this edition: US soon will issue proposed regulations to treat foreign-owned single-member LLCs as corporations, solely for reporting under Section 6038A – IRS updates list of countries for automatic exchange of tax info on bank interest paid to NR aliens – IRS issued annual report on APAs – House Ways and Means Subcommittee announces tax reform hearing 13 April.

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.

A review of the week's major US international tax-related news. In this edition: US international tax reform draft delay – Technical Corrections to Path Act coming soon; FIRPTA corrections not expected – OECD peer review process to monitor resolution of MAP cases "well advanced".

A review of the week's major US international tax-related news. In this edition: US Treasury reviewing Section 891 in context of EU State aid investigations – Treasury Secretary says legislation necessary to stem corporate inversions – US will cancel sharing of CbC reports with any country that publicly discloses data.

A review of the week's major US international tax-related news. In this edition: US to finalize CbC reporting regulations by 30 June – EU denies targeting US multinationals in State aid investigations – US removes Cuba from list of countries denying foreign tax credits, CFC deferral -- IRS issues Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities (2016).

A review of the week's major US international tax-related news. In this edition: US international tax reform takes center stage in Congress -- Treasury will not renegotiate pending tax treaties and protocols following release of new US Model treaty -- IRS files appeal in Altera Corp. v. Commissioner – IRS issues final regulations under Code Section 6038D.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to begin drafting international tax reform legislation immediately – Newly revised US Model Income Tax Treaty released – Treasury official comments on EU State Aid investigations.

A review of the week's major US international tax-related news. In this edition: President Obama releases FY 2017 Budget – Treasury Secretary Lew testifies before two Congressional tax-writing committees on President's FY 2017 budget proposal – Special counsel to IRS associate chief counsel (international) John Merrick talks about anti-inversion guidance at PLI conference in NYC – Former EY national director of International Tax Services Margie Rollinson is named new IRS associate chief counsel (international).

A review of the week's major US international tax-related news. In this edition: House tax reform leadership forming – Treasury official delivers State Aid concerns to EU – IRS issues guidance on partnership allocations of creditable foreign tax expenditures under Section 704 – Treasury poised to release updated US Model Tax Treaty – IRS to accept bilateral APA applications with India beginning 16 February.

A review of the week's major US international tax-related news. In this edition: European Commission releases major anti-tax avoidance package -- 31 countries sign Multilateral Competent Authority Agreement for automatic exchange of CbC reports -- Senate Finance Committee draft corporate integration plan could be developed within a few months – US anti-inversion regulations to be released soon .

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee reviewing options for corporate tax integration – House Ways and Means to hold hearings on inversions, repatriation in 2016; names Chief Tax Counsel – IRS Notice 2016-10 announces forthcoming regulations on RICs’ foreign tax refunds.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee Chairman says international tax reform bill mark-up coming in 2016 – President Obama delivers final State of the Union Address – US Treasury considering a foreign goodwill exception in final Section 367 regulations.

A review of the week's major US international tax-related news. In this edition: Congress returns to session; international tax reform under discussion – US MNC will owe $86 million in withholding tax, plus interest, in stipulated Tax Court decision – Sixth Circuit reverses Tax Court, concludes FX option can qualify as foreign currency contract.

A review of the week's major US international tax-related news. In this edition: IRS will no longer apply 1% excise tax to retrocession agreements between two foreign reinsurance companies – Congressional tax leader introduces bill to delay US country-by-country reporting until 2017.

A review of the week's major US international tax-related news. In this edition: US releases proposed country-by-country (CbC) reporting regulations – House tax leader says international tax reform next on the agenda – More upcoming international tax guidance coming.

A review of the week's major US international tax-related news. In this edition: US Congress passes tax extenders legislation – Treasury officials offer insights on tax treaty negotiations, anti-corporate inversion guidance and EU state aid investigations.

A review of the week's major US international tax-related news. In this edition: Temporary tax extenders legislation on hold pending Congressional negotiations over more comprehensive package – IRS official previews upcoming international tax guidance.

A review of the week's major US international tax-related news. In this edition: Congressional hearings highlight concern over BEPS, EU State aid investigations and inversions –Negotiations continue on bipartisan tax extenders package.

A review of the week's major US international tax-related news. In this edition: Congressional leaders, Obama Administration negotiating tax extenders deal -- House and Senate to hold hearings on OECD BEPS project -- Delayed applicability date for aspect of Section 871(m) dividend equivalent payment regulations – IRS upgrades FATCA Online Registration System.

A review of the week's major US international tax-related news. In this edition: US Treasury releases additional anti-corporate inversion guidance – Tax extenders legislation delayed until December – Speaker calls for House passage of tax reform before Republicans choose a presidential candidate.

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee approves eight proposed tax agreements -- Possibility to link US international tax reform and tax extenders legislation before year-end.

A review of the week's major US international tax-related news. In this edition: New Ways and Means Committee Chairman to tackle tax extenders – House approves 6-year highway bill; formal conference committee with Senate expected – White House releases text of Trans-Pacific Partnership – Treasury may narrow proposed rule eliminating exception for outbound transfer of goodwill.

A review of the week's major US international tax-related news. In this edition: W&M Committee Chairman Paul Ryan elected House Speaker – Senate Foreign Relations Committee holds hearing on eight tax treaties and protocols - US Treasury reviewing new UK Diverted Profits Tax to determine its creditability for US FTC purposes.

A review of the week's major US international tax-related news. In this edition: W&M Committee Chairman Paul Ryan will run for House Speaker -- IRS to begin targeting inbound middle market companies for TP exams in regard to distribution functions -- IRS will begin accepting bilateral APAs with India beginning January 2016 – EU Commission issues anticipated decisions in State aid cases relating to Luxembourg and Netherlands -- US will participate in drafting of multilateral instrument under OECD BEPS Action 15.

A review of the week's major US international tax-related news. In this edition: G20 Finance ministers endorse final package of BEPS deliverables – Recent legislation creates new FBAR filing date, extension option

A review of the week's major US international tax-related news. In this edition: OECD releases final BEPS reports – Nearly half of surveyed tax directors plan significant changes to tax profile due to BEPs -- Tax agenda uncertain with House leadership in flux – Ways and Means Committee Chairman urged to seek House Speakership.

A review of the week's major US international tax-related news. In this edition: Speculation whether US House leadership change may impact limited tax reform package in this Congress – OECD set to release final reports on all 15 BEPS Actions – IRS announces additional Exchange Agreements with 16 countries.

A review of the week's major US international tax-related news. In this edition:IRS Notice 2015-66 announces extension of certain FATCA transitional rules – US announces FATCA Competent Authority Agreements with Australia, UK -- US district court rules denial of discretionary tax treaty benefits subject to judicial review – UK HMRC brief explains treatment of US LLCs following UK Supreme Court decision in George Anson v HMRC (2015).

A review of the week's major US international tax-related news. In this edition: IRS final and temporary regulations under Section 871(m) issued on dividend equivalents – IRS issued final Section 368 “F” reorganization regulations -- House Ways and Means Committee approves bills to make permanent Subpart F active financing exception and CFC-to-CFC look-through rule.

Final OECD BEPS deliverables to be released 5 October – Congress returns from August recess to possibility of US international tax reform – IRS issues final Section 988(d) regulations -- Second Circuit affirms Tax Court in two foreign tax credit generator cases.

IRS releases final and temporary Subpart F regulations -- Congress returns 8 September to various pending deadlines – Final OECD BEPS deliverables slated for release this fall.

A review of the week's major US international tax-related news. In this edition: US Congressional tax leaders express concern over Treasury plans for CbC reporting regulations – IRS CCA addresses “relation back” doctrine in Section 905(c) -- IRS FFA concludes portions of intercompany referral fee income generated by foreign subs improperly characterized as Subpart F income – IRS releases more international tax "practice units".

A review of the week's major US international tax-related news. In this edition: Congress returns on 8 September to series of legislative and budgetary deadlines – Ways and Means international tax reform plan to be drafted in September; markup in October.

A review of the week's major US international tax-related news. In this edition: IRS finalizes two revenue procedures related to requesting assistance from the US competent authority under US tax treaties and requesting an APA – US Court of Appeals for the Federal Circuit affirms decision in Albemarle Corp. v. United States case.

A review of the week's major US international tax-related news. In this edition: Treasury Department releases 2015-2016 Priority Guidance Plan – IRS and Treasury release Notice 2015-54 – Senate Finance Committee’s tax extenders bill, the Tax Relief Extension Act of 2015, gets filed in the Senate – Tax Court makes decision in Altera v. Commissioner case.

A review of the week's major US international tax-related news. In this edition: Senior House Ways and Means Committee members released an “innovation box” discussion draft -- Senate subcommittee held a hearing on “Impact of the US Tax Code on the Market for Corporate Control and Jobs.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves 2-year tax extenders bill -- Senate to consider 6-year highway authorization bill; contrasts with House approach – US Treasury official outlines upcoming international tax guidance.

A review of the week's major US international tax-related news. In this edition: House passes interim highway funding bill to allow for long-term funding plan tied to international tax reform – Senate Finance Committee releases Chairman’s Mark of “tax extenders” bill; committee markup 21 July – Finance Committee chairman voices BEPS concerns on Senate floor.

A review of the week's major US international tax-related news. In this edition: Senate Finance tax reform working groups release final reports, including international tax – US, Vietnam sign first-ever tax treaty.

A review of the week's major US international tax-related news. In this edition: Congress to return from recess to tackle Highway Trust Fund; repatriation, international tax reform possible revenue sources -- Deadline for Senate Finance Committee’s tax reform working groups pushed to early July -- World Customs Organization publishes Guide to Customs Valuation and Transfer Pricing – Possible ‘Grexit’ has FX implications.

A review of the week's major US international tax-related news. In this edition: House W&M subcommittee hearing looks to repatriation to fund Highway Trust Fund – Senate Finance Committee working group on international tax reform hands in report – Legislation introduced to close PFIC “loophole” reportedly used by US hedge fund reinsurers.

A review of the week's major US international tax-related news. In this edition: W&M Chairman says US international tax reform and making tax extenders permanent will dominate 2015 tax agenda in Congress -- IRS may require CbC reports to be filed with corporate returns in September 2017 – Public comments on proposed changes to US Model Tax Treaty due 15 September 2015.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group will present findings on 26 June -- House Ways and Means Committee international tax reform component will propose hybrid territorial tax system with broad innovation box – Congressional tax leaders relay concern over BEPS to Treasury – OECD releases CbC reporting implementation package – G7 Leaders reaffirm commitment to BEPS.

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: US Treasury releases new Model Tax Treaty provisions – US business tax reform in 2015 may be limited – OECD releases revised discussion draft on Action 7, artificial avoidance of PE status.

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 passes House-Senate conference report with reconciliation instructions – IRS issues Rev. Rulings 2015-09 and 2015-10 clarifying certain cross-border internal restructurings.

A review of the week's major US international tax-related news. In this edition: IRS this week releases Notice 2015 – House of Representatives on 30 April passes the House-Senate conference agreement on the FY 2016 budget resolution addressing tax reform and tax extenders – the OECD releases discussion draft on cost contribution arrangements in connection with Action 8 (transfer pricing aspects of intangibles) under its Action Plan on BEPS.

A review of the week's major US international tax-related news. In this edition: IRS issues proposed PFIC insurance regulations that address Senate Finance Committee member’s concerns – IRS releases proposed regulations under Section 5000C – IRS CCA 201516064 clarifies short term loan exception under IRS Notice 88-108.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group reviewing options - IRS confirms interaction of PFIC look-through rules in PLR 201515006 - OECD releases discussion draft on Action 11(Improving the analysis of BEPS).

A review of the week's major US international tax-related news. In this edition: Congress returns from 2-week recess; Senate Finance tax reform working groups resume work -- OECD releases Discussion Draft on CFC rules under Action 3.

A review of the week's major US international tax-related news. In this edition: OECD releases Discussion Draft on Action 12 (Disclosure of aggressive tax planning arrangements) – US officials comment on BEPS Actions 8, 9, 10.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee leaders offer international tax reform insights -- OECD holds public consultation on BEPS Actions 8-10 on transfer pricing -- US will focus on international tax administration and mutual agreement procedures post-BEPS.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee focuses on international tax reform – Fifth Circuit Court of Appeals reverses Tax Court in BMC Software; A/R created following transfer pricing adjustment does not constitute indebtedness for Section 965 purposes – US Treasury official: 25 countries may be interested in mandatory binding arbitration based on multilateral instrument.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee Chairman has concerns over Obama Administration’s international tax proposals – Finance Committee requesting tax ideas on tax reform; international hearing slated for 17 March -- IRS to begin scheduling pre-filing conferences for bilateral APAs with India – US opposes risk, recharacterization, and special measures draft under BEPS actions 8, 9, and 10, but consensus still possible.

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.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee tax reform working groups set May deadline – Treasury officials offer US positions on OECD BEPS.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman says tax reform in 114th Congress must happen before August recess -- IRS concludes US shareholder must increase its E&P in year of Section 951(a)(1) inclusion -- IRS opines on application of tax rate disparity test for foreign sales branches – US anti-corporate inversion regulations may be released in 2015 – New IRS APMA director appointed.

A review of the week's major US international tax-related news. In this edition: IRS finalizes regulations under Section 909 on foreign tax credit splitting events --- China issues long-awaited indirect transfer rule replacing Circular 698

A review of the week's major US international tax-related news. In this edition: Obama Administration releases FY 2016 Budget, including international tax proposals – Ways and Means Committee holds hearing on proposed FY 2016 Budget – Treasury official offers insight on future anti-inversion regulations – OECD releases three more BEPS papers.

A review of the week's major US international tax-related news. In this ed(See attached file: 04 - Week ending 30 Jan.wav.zip)ition: President Obama to release FY 2016 Budget on 2 February - Finance Committee Chairman Orrin Hatch offers insights on tax working groups, international tax reform.

A review of the week's major US international tax-related news. In this edition: Obama Administration, Congressional Republican leaders stake out positions on future tax reform debate – US, India agree on framework to resolve competent authority cases; clears way for US-India APAs.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans talk tax reform – President Obama to deliver State of Union Address on 20 January -- The Stop Tax Haven Abuse Act reintroduced in Congress -- IRS launches FATCA International Data Exchange Service.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes -- Sen. Hatch assumes chairmanship of Finance Committee -- FATCA developments -- IRS CCA 201501013: Foreign fund’s activities through US fund manager constitute US trade or business.

A review of the week's major US international tax-related news. In this edition: 114th Congress convenes 6 January – IRS releases PLR 20145200002 on FTC recapture.

A review of the week's major US international tax-related news. In this edition: President Obama announces Administration will release specific proposals on tax reform – Tax extenders legislation signed into law – IRS releases final regulations (T.D. 9707) with respect to filing of Form 5472.

A review of the week's major US international tax-related news. In this edition: Congress enacts tax extenders legislation -- Obama Administration may release detailed business tax reform plan in 6-9 months - Incoming Senate Finance Committee Chairman discusses guidelines for tax reform -- IRS officials offer thoughts on inversion guidance -- OECD releases 6 BEPS discussion drafts.

A review of the week's major US international tax-related news. In this edition: Congress poised to pass tax extenders legislation -- Incoming Senate Finance Committee Chairman releases tax reform report -- OECD BEPS update -- IRS updates FATCA Q&As on withholding certification forms -- SEC says more disclosure about foreign taxes may be necessary -- UK releases more details on diverted profits tax proposal; significance for US multinationals.

A review of the week's major US international tax-related news. In this edition: House approves one-year tax extenders legislation -- IRS announces jurisdictions treated as having FATCA IGA, but not yet signed, will retain status beyond 31 December 2014 -- UK Autumn Statement includes new 'diverted profits tax' proposal.

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.

A review of the week's major US international tax-related news. In this edition: Tax extender negotiations continue in Congress -- Rep. Paul Ryan to chair Ways & Means Committee, Sen. Orrin Hatch to lead Finance Committee in 114th Congress -- IRS issues final and temporary regs on failure to file timely GRAs, other reporting; IRS Directive on GRAs revoked -- IRS issues CCA 201446020 on back-to-back loans to avoid Section 956.

A review of the week's major US international tax-related news. In this edition: Congress begins lame-duck session; tax extenders under negotiation -- House may consider REIT/PFIC change -- IRS finalizes regulations on all-cash D reorganizations -- Treasury continues work on anti-inversion guidance -- Treasury considering limited FATCA relief for IGAs in substance -- BEPS communique expected following G20 Finance Ministers meeting -- UK, Germany release IP proposal -- OECD releases BEPS strategy for including developing countries.

A review of the week's major US international tax-related news. In this edition: Obama Administration continuing to move forward on potential guidance to curb corporate inversion transactions -- 51 jurisdictions pledge to abide by automatic tax information exchange.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee considering need for anti-inversion stop gap measure -- US Claims Court in Albemarle rules contested foreign tax liability accrues in year to which it relates, not year resolved and paid.

A review of the week's major US international tax-related news. In this edition: Treasury notifies 17 Model I IGA jurisdictions of MFN option -- IRS CCA 201441015 disallows domestic parent's deemed paid foreign taxes paid -- Ireland's FY'15 Budget includes improvement to IP regime, phasing out of "double Irish".

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-58 on economic substance -- FATCA developments reviewed -- OECD updates calendar for draft BEPS discussion papers, public consultations -- EY conference participants polled on BEPS.

A review of the week's major US international tax-related news. In this edition: US government officials offer perspectives on OECD BEPS action items.

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-52 to counter corporate inversions -- Treasury considering expanding covered asset acquisition rules under Section 901(m); PFIC guidance coming -- EY Alerts / Webcasts on OECD BEPS deliverables available -- Congress adjourns for mid-term elections; lame duck session may bring tax technical corrections.

A review of the week's major US international tax-related news. In this edition: OECD releases BEPS deliverables in 7 focus areas -- Obama Administration confirms it will address inversions shortly.

A review of the week's major US international tax-related news. In this edition: Congress returns from August recess; focuses on anti-inversion options -- OECD to release first seven deliverables under BEPS Action Plan on 16 September 2014 -- IRS issued CCA 201436047; accrued but unpaid interest is an obligation under Section 956 -- IRS Notice 2014-51 announces PFIC marked to market exception

A review of the week's major US international tax-related news. In this edition: Congress returns next week from August recess -- OECD to release multiple BEPS reports and recommendations during week of 15 September.

A review of the week's major US international tax-related news. In this edition: IRS releases 2014-2015 Priority Guidance Plan -- IRS finalizes rules applying straddle rules to certain debt instruments -- IRS addresses when late-received documentation can support portfolio interest exemption.

A review of the week's major US international tax-related news. In this edition: Congress returns after Labor Day for short session -- Proposed anti-inversion legislation expected in September.

A review of the week's major US international tax-related news. In this edition: Senator Charles Schumer releases outline of his legislative proposal to address inversions by targeting earnings stripping practices -- IRS releases its first private letter ruling on Section 7874 anti-inversion rules – IRS issues Revenue Procedus pa014-47 that provides guidance for entering into a withholding foreign partnership agreement and withholding foreign trust agreement with the IRS -- EY publishes a Global Tax Alert discussing the Standard for Automatic Exchange of Information in Tax Matters paper released by the OECD on 21 July 2014.

A review of the week's major US international tax-related news. In this edition: Congressman Levin releasesdiscussion draft of legislation that would tighten the earnings stripping rules of Section 163(j) -- Obama Administration reviews possible actions that could limit companies’ ability to engage in inversions – OECD releasesreport on the impact of BEPS in low income countries -- OECD seeking input on collecting and analyzing data on BEPS as part of Action 11 of BEPS Action Plan.

A review of the week's major US international tax-related news. In this edition: Congress mulls anti-inversion options -- IRS will apply forthcoming FTC regulations to certain entity classification elections following covered asset acquisitions -- OECD BEPS report on digital economy will not propose new tax regime.

A review of the week's major US international tax-related news. In this edition: Corporate inversions dominate Senate Finance Committee hearing -- IRS Notice 2014-44 announces forthcoming regulations under Section 901(m) -- IRS names acting director of transfer pricing operations -- OECD publishes Standard for Automatic Exchange of Financial Account Information in Tax Matters.

OECD publishes Standard for Automatic Exchange of Financial Information in Tax Matters

A review of the week's major US international tax-related news. In this edition: Growing anti-inversion sentiment in Congress -- IRS issues final regulations under Section 861 -- CCA: IRS can notify w/holding agent of foreign taxpayer's incorrect claim of w/holding tax exemption -- OECD Council approves update to OECD Model Tax Treaty -- IRS official offers international guidance update.

There were several Mexican tax developments that took place on 4 July 2014, affecting maquiladoras among other changes.

A review of the week's major US international tax-related news. In this edition: Speculation on departures of top international IRS officials -- House Ways and Means Committee and Senate Finance Committee pass separate highway funding bills.

A review of the week's major US international tax-related news. In this edition: IRS releases FATCA guidance in run up to 1 July 2014 effective date -- Shakeup at the IRS Large Business and International Division -- US Congress to take up Highway Trust Fund after 4 July recess.

A review of the week's major US international tax-related news. In this edition: US and China reached agreement in substance on FATCA Model 1 IGA -- Corporate repatriation appears off radar to sustain Highway Trust Fund -- Final regs to change rules for failure to comply with GRAS, other filings "imminent".

A review of the week's major US international tax-related news. In this edition: Congress mulls repatriation to pay for Highway Trust Fund -- US Senate Foreign Relations Committee holds hearing on Spanish protocol, new Polish tax treaty -- Treasury official: Solutions for all BEPS issues may not be possible.

A review of the week's major US international tax-related news. In this edition: Congress mulls tax repatriation to pay for Highway Trust Fund -- FATCA audits to begin early 2016 -- European Commission begins state aid investigations for Ireland, Netherlands, and Luxembourg regarding corporate tax paid by three MNCs.

A review of the week's major US international tax-related news. In this edition: House, Senate leaders concerned about BEPS -- OECD Tax Conference confirms 2014 BEPS action items timeline -- Pending US tax treaties and protocols (again) blocked in Senate -- Finance Committee announces summer tax reform hearings -- Senate Majority Leader says tax extenders "dead" until after mid-term election -- IRS publishes list of registered FFIs; more FATCA guidance coming in June.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves more permanent tax extender bills; Chairman Camp moves to "incremental tax reform" approach -- IRS to permit financial institutions to use existing forms through 2014 to sort entity accounts for FATCA purposes.

A review of the week's major US international tax-related news. In this edition: US anti-inversion legislation introduced in House and Senate -- Update on tax extenders -- OECD holds two public consultations: on hybrid mismatch arrangements and TP documentation and country-by-country reporting -- Proposed 2013 US-Poland tax treaty transmitted to Senate.

A review of the week's major US international tax-related news. In this edition: Tax extenders and corporate inversions dominate Congressional tax debate – US government officials offer insights at ABA Tax Section meeting.

On 6 May 2014, a declaration on automatic exchange of information in tax matters was adopted at the meeting of the OECD Council at the Ministerial Level; it was endorsed by 48 countries and the EU.

In Notice 2014-33, the IRS announced it will treat calendar years 2014 and 2015 as a transition period for purposes of enforcing and administering implementation of FATCA by all withholding agents (including foreign financial institutions).

A review of the week's major US international tax-related news. In this edition: Proposed US tax agreements delayed in Senate (again) -- US-Spain protocol transmitted to Senate -- Senate to move on tax extenders package next week -- US corporate inversions attract Congressional attention -- IRS Proposed Section 381 regulations have international implications.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee approves six separate bills to make permanent certain expired business tax provisions -- IRS official says BEPS causing some treaty partners to take aggressive positions -- IRS's top FACTA priority is release of final forms and instructions.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to mark-up tax extenders soon -- Senate tax extenders bill to go to floor week of 28 April -- IRS Notice 2014-32 addresses foreign triangular reorganizations -- IRS extends expanded PFIC active banking exception for qualifying government bonds.

On 16 April 2014, the Australian Taxation Office (ATO) released two new draft transfer pricing Taxation Rulings and new two draft Practice Statements, which represent the ATO’s first documented view on how the new transfer pricing laws will apply and what taxpayers need to do.

A review of the week's major US international tax-related news. In this edition: IRS announces filing exemption for US persons holding PFIC stock through exempt orgs / accounts -- Immediate action for Mexican IMMEX/maquiladora companies.

China and Germany on 28 March 2014 signed a new income tax treaty and protocol; it will become effective on or after 1 January following the year in which the new treaty enters into force.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee hearing reviews tax extenders -- Official offers US perspective on OECD BEPS action items,

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves tax extenders legislation -- House Budget Committee Chairman releases FY 2015 Budget Resolution -- IRS Announcement 2014-17 offers FATCA relief -- Senate Foreign Relations Committee reports five pending tax agreements out of committee -- OECD tentatively decides to make simplifications to CbC reporting template.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to mark-up tax extenders next week -- OECD issues digital economy discussion draft -- 34 countries commit to early adopt OECD Common Reporting Standard -- IRS says Bitcoin not a "real currency" -- US, HK sign TIEA.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to hold mark up of tax extenders package -- OECD releases discussion BEPS drafts on treaty abuse and hybrid mismatch arrangements - UK releases 2014 Budget.

On 12 March 2014, the Italian Government announced that the 20% flat tax currently applicable to dividends, interest, and certain capital gains will increase to 26%.

A review of the week's major US international tax-related news. In this edition: Update on US tax reform, tax extenders - OECD to issue discussion drafts on treaty abuse, digital economy, and hybrid mismatches in coming weeks.

The Italian Government, With Law Decree no. 16 of 6 March 2014, repealed part of the recently introduced tax rules concerning certain Digital Economy activities generally referred to as "Web Tax."

A review of the week's major US international tax-related news. In this edition: President Obama releases FY 2015 Budget -- IRS issues Notice 2014-14, announcing proposed Section 871(m) regulations will not apply to specified equity-linked instruments on 5 March 2014.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman releases comprehensive tax reform draft -- Senate Foreign Relations Committee holds treaty hearing -- President Obama to submit FY 2015 Budget Proposal on 4 March -- G20 expresses full support for OECD BEPS.

A review of the week's major US international tax-related news. In this edition: Ways and Means Committee Chairman Dave Camp poised to release comprehensive tax reform draft -- US Senate Foreign Relations Committee to hold long-awaited tax treaty hearing -- IRS issues final FATCA guidance.

On 11 February 2014, the Canadian government released the 2014 Federal Budget.

A review of the week's major US international tax-related news. In this edition: Chairman Camp expected to release comprehensive tax reform proposal before end of February -- Congress passes "clean" debt ceiling increase -- OECD releases "Standard for Automatic Exchange of Financial Account Information" -- IRS releases transfer pricing audit roadmap -- Canada issues 2014-2015 Federal Budget.

The US and Canada on 5 February 2014 signed an Intergovernmental Agreement (IGA) regarding the enhanced exchange of tax information in connection with the Foreign Account Tax Compliance Act (FATCA).

A review of the week's major US international tax-related news. In this edition: Future of US tax reform and tax extenders under a new Senate Finance Committee Chairman -- Prediction that US international tax reform will move forward in 2014 -- US signs FATCA IGAs with Canada, Hungary -- US debt limit reached 7 February -- EY to host webcast on OECD BEPS on 18 February.

A review of the week's major US international tax-related news. In this edition: President Obama to deliver State of the Union 28 January -- Treasury Secretary issues warning on debt limit -- Tax extenders legislative may be a possibility -- OECD hosts webcast on BEPS; digital economy focus not abandoned.

The Canadian government on 17 January 2014 launched a new Offshore Tax Informant Program targeting offshore tax evasion.

A review of the week's major US international tax-related news. In this edition: Congress Congress approves "omnibus" spending bill -- IRS issues temporary inversion regulations US, Italy sign FATCA Model 1 IGA.

The Colombian government recently issued two tax-related decrees that may have an impact on multinational companies investing in Colombia.

A review of the week's major US international tax-related news. In this edition: Congress back in session -- status of tax reform and tax extenders

A review of the week's major US international tax-related news. In this edition: IRS issues temporary and proposed PFIC reporting regulations -- Congress to reconvene second sesssion of 113th Congress -- Two international tax extenders expired on New Year's Eve.

A review of the week's major US international tax-related news. In this edition: IRS releases final FACTA foreign financial institution agreement in Rev. Proc. 2014-10 -- President Obama signs Bipartisan Budget Act of 2013-- Finance Committee Chairman Max Baucus formally nominated to be next US ambassador to China.

A review of the week's major US international tax-related news. In this edition: Senate passes Bipartisan Budget Act of 2013-- W&M Chairman opposes increase in capital gains rate -- Finance Committee Chairman to be named next US ambassador to China -- No tax extenders legislation this year -- US signs 6 FATCA IGAs.

On 11 December 2013, the final components of Mexico’s 2014 tax reform were published in the Official Gazette, after having been signed by President Peña Nieto on 6 December 2013.

A review of the week's major US international tax-related news. In this edition: House approves budget deal -- IRS issues guidance on treatment under Sections 482 and 901 of transactions with foreign branches or disregarded entities.

On 5 December 2013, the UK Chancellor delivered his Autumn Statement, setting out a number of economic reforms with the aim of bringing down the deficit.

A review of the week's major US international tax-related news. In this edition: No House Ways & Means Committee tax reform draft legislation this year -- IRS issues final and proposed Section 871(m regulations addressing dividend equivalent payments on notional principal contracts, other equity-linked instruments.

A review of the week's major US international tax-related news. In this edition: House-Senate FY'14 budget conference committee deadline little over two weeks away -- IRS official says US, Indian competent authorities attempting to "normalize" relations -- Guidance under Section 901(m) on covered asset acquisitions,Section 905(c) on foreign tax redeterminations delayed.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee Chairman releases discussion draft on international tax reform -- US government reportedly has initialed 33 FATCA IGAs -- US, Vietnam to enter into tax treaty negotiations.

A review of the week's major US international tax-related news. In this edition: OECD holds public consultation on BEPS-related reporting and transfer pricing issues -- Update on US tax reform -- US, France announce signing of Model 1 FATCA IGA - Brazil publishes PM 627 with major corporate tax implications -- EY launches Global R&D Guide on ey.com.

The Australian government on 6 November 2013 said it would address the extensive backlog of previous tax and superannuation policy decisions announced, but not legislated by previous governments.

A review of the week's major US international tax-related news. In this edition: Senate Finance Committee to release first tax reform draft within two weeks -- IRS rules there is a reduction in CFC's post-1986 foreign taxes corresponding to reduction in earnings from stock redemption.

On 30 October 2013, Law 16/2013 was published in the Spanish Official Gazette; it introduces relevant amendments to Spanish corporate income tax and extends the application of certain measures to FY 2014 and 2015.

A review of the week's major US international tax-related news. In this edition: House-Senate conference committee holds first meeting - Senate Finance Committee to release tax reform drafts in coming weeks - IRS issues Notice 2013-69 on FATCA - US, Hungary initial FATCA Model 1 IGA -- Mexican Congress approves tax reform

A review of the week's major US international tax-related news. In this edition: IRS rules certain growing activities qualify as production for subpart F foreign base company sales income rules -- ILM 201340016 considers triangular C reorg completed before release of Notice 2006-85 -- Update on Ireland's change to the Irish tax residency rules.

India’s Central Board of Direct Taxes (CBDT) recently issued a notification for application of General Anti-avoidance Rules (GAAR).

Mexico’s lower House of Congress revised and approved the proposed tax reform on 18 October 2013; it now moves on to the Senate for debate and vote.

A review of the week's major US international tax-related news. In this edition: Congress approves funding / debt bill; government reopens -- Ireland proposes change to tax residency rule to prevent "stateless" entities -- Italian Law Decree includes changes of interest to MNCs.

A review of the week's major US international tax-related news. In this edition: Movement on US fiscal impasse -- OECD country-by-country reporting may begin as early as 2014.

On 3 October 2013, the OECD published a memorandum seeking input on the development of an approach for country-by-country reporting of income, taxes paid, and economic activity.

An EY review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House; US opposes "virtual PE" concept and more.

A review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House -- US opposes "virtual PE" concept -- IRS concerned re: taxpayers unwinding so-called "sandwich structures" -- Two courts address STARS transactions.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans may tie movement on tax reform to legislation to raise the debt limit - Tax Court rules in BMC Software that accounts set up from Section 482 adjustment are related party indebtedness for Section 965 DRD.

In an opinion dated 6 September 2013, the European Council’s lawyers concluded that the proposed Financial Transaction Tax counterparty rule is contrary to EU law.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess; no progress on fiscal issues -- IRS CCA looks at interest expense allocation / apportionment for FTC purposes -- Prop. regulations issued on limitations on importation of net built-in losses; international tax implications.

On 8 September 2013, Mexico’s President Pena Nieto presented the long-awaited tax reform proposal to the Mexican Congress.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess to looming fiscal deadlines -- IRS issues final 901 regulations -- Final, temporary, and proposed regulations on application of straddle rules to debt instruments released.

A review of the week's major US international tax-related news. In this edition: US tax reform update -- IRS CCA concludes interest deductions on payments by US corporation to foreign parent disallowed under Section 267(a)(3) .

A review of the week's major US international tax-related news. In this edition: House and Senate committees continue work on tax reform during August recess -- IRS announces FATCA registration site available online.

A review of the week's major US international tax-related news. In this edition: US, Cayman Islands sign FATCA Model 1 IGA and TIEA -- IRS releases draft Form 8966 FATCA Report -- IRS releases PLR 201332007; addresses subpart F foreign base company sales branch rules.

A review of the week's major US international tax-related news. In this edition: A review of the status of US tax reform -- US, Belgium sign Competent Authority Agreement -- Urgent action by US and foreign MNCs may be required due to new Canadian upstream loan rules.

The Italian Revenue Agency issued its annual guidelines for Revenue auditors on goals to achieve and tax strategies to pursue in the carrying out of FY 2013 audit activities.

A review of the week's major US international tax-related news. In this edition: President Obama offers business tax reform proposal -- Congress begins August recess; tax reform markups for fall -- OECD issues TP discussion draft on intangibles, White Paper on documentation.

A review of the week's major US international tax-related news. In this edition: More on US tax reform and the recently released OECD base erosion and profit shifting (BEPS) action plan.

A review of the week's major US international tax-related news. In this edition: OECD released BEPS action plan on 19 July -- Treasury updated FATCA Model 1 and 2 IGAs -- IRS issues both FAA on CFC income from software leases determined to be foreign personal holding company income and GLAM on ADR Payments.

A review of the week's major US international tax-related news. In this edition: OECD to release BEPS action plan on 19 July -- Key FATCA timelines delayed -- Senate leaders say tax reform a long way off.

A review of the week's major US international tax-related news. In this edition: Congressional tax leaders kick-off of nation-wide tax reform tour -- OECD BEPS report due out next week -- IRS PLR addresses subpart F manufacturing exception -- IRS adds Croatian entity to per se list of corporations

A review of the week's major US international tax-related news. In this edition: Senate tax leaders favor "clean slate" approach to tax reform, FATCA developments, US Tax Court has jurisdiction to review APA cancellation, and US government opposes public disclosure of country-by-country tax reporting.

A review of the week's major US international tax-related news. In this edition: an update on the recent G8 meeting in Northern Ireland at which the G8 expressed support for greater transparency with tax authorities and endorsed the OECD’s ongoing work on base erosion and profit shifting (BEPS).

The European Commission on 12 June 2013 proposed extending automatic exchange of information to cover dividends, capital gains, and other financial income and account balances.

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee on 13 June held a hearing on US and foreign multinational corporations' use of tax havens, Congressional leaders stake out positions on raising US debt ceiling, and US, Japan sign Model 2 IGA "statement."

The Russian government recently released a draft document that discusses tax policy changes for 2014 and planning for the 2015-16 period.

A review of the week's major US international tax-related news. In this edition: OECD conference focuses on Base Erosion and Profit Shifting (BEPS), House Ways and Means moves a bit on US tax reform, and PLR 201321007 on domestication of a foreign parent corporation holding a USRPHC.

The European Union may be considering expanding tax reporting obligations already adopted for banks to all large companies and groups

United Nations launches Practical Manual on Transfer Pricing for Developing Countries

A review of the week's major US international tax-related news. In this edition: an update on the OECD's Base Erosion and Profit Shifting Action Plan, release of the UN Practical Manual on Transfer Pricing for Developing Countries, and IRS CCA 210321018.

A review of the week's major US international tax-related news. In this edition: the US Supreme Court rules the UK windfall tax is creditable, US FATCA developments, and the OECD's release of final guidance on transfer pricing safe harbors.

Australia issues 2013/14 Federal Budget

Swiss Corporate Tax Reform III: increasing Switzerland’s attractiveness as a business location