A monthly review of US international tax-related developments. In this edition: US Congress begins August recess – US Supreme Court overrules Chevron deference to agency regulations – US appellate court rules NR’s gain from sale of its US partnership interest attributable to inventory is not US source income – IRS final Section 367(b) regs address …

A monthly review of US international tax-related developments. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – US Supreme Court upholds Section 965 mandatory repatriation tax – IRS finalizes regs on reporting / payment of stock repurchase excise tax – IRS releases final digital asset broker reporting regulation…

A monthly review of US international tax-related developments. In this edition: US House Republicans prepare for TCJA ‘cliffs’ – White House official previews President Biden’s tax policy for second term – US House Ways and Means Chairman, Treasury Secretary spar over TCJA, BEPS 2.0 – US will not sign BEPS Pillar One MLC without India, China TP res…

A monthly review of US international tax-related developments. In this edition: US tax policy battle lines being drawn; House Republican tax writers form 10 TCJA ‘tax teams’ – US progress on global minimum tax will positively affect ongoing R&D talks, JCT updating BEPS Pillar Two analysis – IRS releases proposed rules on stock repurchase excise tax…

A monthly review of US international tax-related developments. In this edition: President Biden delivers State of the Union; releases FY2025 Budget with international tax proposals – Congress passes final FY2024 funding bills, tax bill in limbo – Treasury Secretary defends Administration’s BEPS position at Senate hearing – House Ways & Means Subpan…

A monthly review of US international tax-related developments. In this edition: OECD releases final guidance on BEPS Pillar One Amount B on baseline distribution – Finalization of proposed FX regulations expected by year end, two sets of proposed Section 367 regs in first half of 2024 – US Senate approves IRS Chief Counsel nomination – IRS sending …

A monthly review of US international tax-related developments. In this edition: US House passes tax package, Senate action uncertain – Congress approves CR to fund government until early March 2024 – IRS signals new Section 367(d) guidance in 2024 on repatriation of IP – US officials provide regulatory update – IRS announces cryptocurrency transact…

A monthly review of US international tax-related developments. In this edition: IRS interim CAMT guidance provides relief from possible double-counting of CFC earnings in AFSI – IRS hasj CAMT compliance initiative – Treasury provides guidance on creditability of BEPS Pillar Two taxes, relief for pre-GloBE DCLs and extends temporary FTC reg relief –…

A monthly review of US international tax-related developments. In this edition: US Congress approves new CR, complicates options for year-end tax bill – House Ways and Means Committee clears US-Taiwan tax bill – Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership WHT – US court denies DRD…

A monthly review of US international tax-related developments. In this edition: OECD releases text of Amount A Pillar One MLC, US Treasury announces consultation – OECD/G20 IF MLC to implement Pillar Two STTR – US House elects new Speaker – US-Taiwan legislation moves forward – IRS proposed regs would amend Section 367(b) rules re cross-border tria…

A monthly review of US international tax-related developments. In this edition: US Senate Finance Committee approves US-Taiwan tax bill – House Republicans want countries to delay BEPS Pillar Two, adopt GILTI-like regime – Senate Finance Committee considers IRS Chief Counsel pick – IRS publishes additional interim guidance clarifying CAMT – IRS ann…

A monthly review of US international tax-related developments. In this edition: US Congress to take up appropriations bills, consider US-Taiwan tax relationship – IRS proposes updating consolidated returns regulations, discarding unnecessary guidance – IRS issues proposed regs on broker reporting requirements for digital asset sales and exchanges –…

A monthly review of US international tax-related developments. In this edition: US Congressional Republicans criticize BEPS 2.0 project – US Senate moves on US-Taiwan tax relations – Congress pivots to crypto assets, requests comments on tax uncertainties – Treasury temporarily delays controversial foreign tax credit regulations – IRS makes permane…

A monthly review of US international tax-related developments. In this edition: US House Ways and Means Republicans release tax package – Congressional JCT provides revenue estimates for BEPS 2.0 Pillar Two – IRS waives addition to tax for corporation’s failure to make estimated tax payments of its CAMT – IRS plans further IP guidance – US Senate a…

A monthly review of US international tax-related developments. In this edition: US Congress passes debt ceiling bill, averts possible default – House Ways & Means Republicans introduce tax increase on foreign companies to influence BEPS 2.0 tax deal – IRS proposed regulations would turn off Section 367(d) following certain IP repatriations – IRS ad…

A monthly review of US international tax-related developments. In this edition: US House Republicans pass debt ceiling, spending bill; impasse continues – IRS provides transition period for documentation requirements for FTC ‘single country exception’ – IRS updates crypto notice, virtual currency remains unavailable to generate FX gain or loss – IR…

A monthly review of US international tax-related developments. In this edition: President Biden releases FY’24 Budget with major international policy proposals – US Treasury official says permanent safe harbor under BEPS Pillar Two GloBE rules unlikely – OECD holds public consultation meeting on BEPS 2.0 global minimum tax compliance and tax certai…

A monthly review of US international tax-related developments. In this edition: President Biden delivers State of the Union address, proposes fourfold increase in stock buyback excise tax, ‘billionaire surtax’ – House Ways and Means Committee Chairman calls BEPS Undertaxed Profits Rule ‘fundamentally flawed’ – Proposed PTEP regulations to be releas…

A monthly review of US international tax-related developments. In this edition: Kevin McCarthy new US House Speaker, Rep. Smith chairs Ways and Means Committee – JCT to release ‘Blue Book’ on tax legislation by end of June – IRS issues final regulations for qualified foreign pension funds – IRS releases proposed regs on domestically controlled QIE …

A monthly review of US international tax-related developments. In this edition: US, Croatia sign income tax treaty – IRS issues interim guidance on CAMT – IRS releases guidance on new stock buyback excise tax – IRS issues final revised QI agreement effective 2023 – IRS releases more guidance for brokers on transfers of PTP interests – IRS issues pr…

A monthly review of US international tax-related developments. In this edition: IRS proposed FTC regulations offer relief from cost recovery and source-based attribution rules, other key changes – IRS moving forward on cryptoasset issues – Section 367(d) regs coming early next year, IRS official says – No delay or transition period for final Sectio…

A monthly review of US international tax-related developments. In this edition: Proposed US FTC regs release expected soon, PTEP regs in first half of 2023 – US Treasury official says proposed crypto regs before year end – IRS may be more selective on APAs given availability of ICAP in transfer pricing disputes – IRS to reconsider APA revenue proce…

A monthly review of US international tax-related developments. In this edition: US tax treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates – IRS PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year – Proposed IRS regulations coming on application of noncompulsory payment regs to certai…

monthly review of US international tax-related developments. In this edition: President Biden signs Inflation Reduction Act with 15% corporate minimum tax – Inflation Reduction Act includes 1% stock buyback excise tax – Congress passes $280 billion Chips and Science Act – Applicability date for FX regs under Section 987 extended again – IRS announc…

monthly review of US international tax-related developments. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740b budget reconciliation bill with 15% corporate minimum tax – Congress passes CHIPS bill with investment tax credits and incentives – Treasury and IRS publish technical corrections to final foreign tax credit …

monthly review of US international tax-related developments. In this edition: Democrats fail to reach consensus on pared-down budget reconciliation package – Treasury Secretary testifies in support of anti-inflationary measures, BEPS 2.0 – US Supreme Court accepts FBAR filing case – IRS to defer reporting for certain derivative payments in forthcom…

monthly review of US international tax-related developments. In this edition: US budget reconciliation remains stalled, but some behind-the-scenes talks – Senators introduce Support Ukraine Through Our Tax Code Act -- More US FTC guidance coming – US officials offer international tax projects update – IRS GLAM addresses allocating/apportioning ‘def…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress returns amid speculation over limited budget reconciliation – Senate proposal would disallow FTCs, other US tax benefits connected with operations in Russia or Belarus – IRS issues annual APA report for 2…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration releases FY2023 Budget with new international tax proposals – Congress passes omnibus appropriations bill with no tax title – Senate Finance Committee Chairman supports tax sanctions for Russia, …

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Senate Democrats backburner Build Back Better, look to address inflation’s impact – G20 confirms BEPS 2.0 ambitious timeline; Republican Senators voice concerns – IRS releases FAQs on Schedules K-2 and K-3 transit…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration looks to scaled-back Build Back Better legislation – House Ways and Means Committee Republicans warn congressional consent needed for BEPS 2.0 Pillars – Final regulations released on treatment of…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration’s Build Back Better legislation stalls in Congress; Senate Finance Committee releases updated international tax provisions – Senate Foreign Relations Committee Republicans urge vote on 2010 US-Ch…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US House passes Build Back Better Act budget reconciliation bill; action moves to Senate – President Biden signs infrastructure legislation including new cryptocurrency reporting – Final FTC regs expected by year-end…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden releases pared down budget reconciliation framework – G20 leaders confirm commitment to global tax changes under BEPS 2.0 – Six country Joint Statement on transitional approach to existing unilateral …

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress fails to pass infrastructure and budget reconciliation legislation -- House Ways & Means Committee reports out reconciliation bill with major international tax proposals -- Senate Finance Committee Chairm…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US infrastructure legislation, FY 2022 budget resolution move forward – Senate Finance Committee Chairman, members release international tax discussion draft – Finance Committee Chairman introduces bill to amend tax …

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: White House, Senate negotiators reach agreement on $1.2 trillion infrastructure package – OECD announces conceptual agreement in BEPS 2.0 project; endorsed by G20 Finance Ministers, Central Bank Governors – US, UK co…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Bipartisan infrastructure deal reached, but road to passage uncertain – House passes corporate disclosure package requiring CbC tax reporting for multinationals – Biden Administration’s proposed 15% minimum tax could…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury ‘Green Book’ offers new details on international tax proposals – Senate hearing discusses Biden Administration’s international tax proposals – House bill would require SEC regulations on CbC financial inf…

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury releases President’s plan to overhaul corporate tax system – US Senators release proposed International Tax Framework – President Biden lays out $1.8 trillion American Families Plan proposal – Senate Fina…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden lays out $2 trillion + infrastructure plan to be paid for with tax increases – Senate Finance Committee holds international tax hearing – Congressional Democrats introduce international tax legislation…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress poised to enact $1.9t COVID relief bill with repeal of worldwide interest expense allocation – Treasury to consider reviving expired transfer pricing aggregation regulations – IRS continues APA/MAP case closu…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary says no new taxes for now, commits to OECD BEPS discussions – New final regulations address application of Section 163(j) limitation to CFCs and partnerships, reserve on certain provisions – IRS …

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax t…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Major policy changes expected following US November election – Treasury and IRS finalize regulations to reduce double taxation caused by anti-abuse rules on GILTI gap period – IRS officials provide international regul…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership i…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Final BEAT regulations adopt proposed BEAT guidance with some changes − New final and newly proposed foreign tax credit regulations released − Treasury issues final sourcing regulations on sales of personal property (…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – Treasury and IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules during GILT…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII a…

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for ‘pause’ in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I …