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 certain cross-border triangular reorgs, inbound nonrecognition transactions – IRS officials offer update on CAMT, PTEP guidance – IRS and Medtronic file Eighth Circuit appellate briefs arguing for different transfer pricing methods – IRS official says corporations failing to respond to TP compliance letters referred for possible examination – G20 Finance Ministers, Central Bank Governors reiterate support for BEPS 2.0 – Inclusive Framework on BEPS finalizing MLC to implement Pillar One Amount A, Amount B consensus near – OECD releases sixth edition of Corporate Tax Statistics publication, Draft User Guide for GloBE Info Return XML Schema.
9 Jul 2024
EY ITTS Washington Dispatch, June 2024
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 regulations, transition relief for certain brokers – IRS addresses certain related-party partnership basis-transactions – IRS extends penalty relief for failure to pay estimated CAMT to installment due August 2024 – US officials comment on pending CAMT guidance – IRS clarifies changes to 2023 QI agreement in new FAQs – US suspends key provisions of US-Russia tax treaty and protocol – OECD/G20 IF releases documents on Pillar One Amount B and Pillar Two – OECD updates FAQs for MNEs participating in ICAP risk assessments.
7 Jun 2024
EY ITTS Washington Dispatch, May 2024
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 resolution – IRS extends transitional relief under Section 871(m) for treatment of dividend equivalents – IRS to defer applicability date re: Sections 59A and 6038A regs for qualified derivative payments – New procedures for Section 355 transaction PLRs released – CAMT regs in advanced stage – Final crypto reporting rules coming in 2024 – IRS proposed regulations on foreign trusts and large foreign gifts released – More OECD BEPS 2.0 GloBE guidance coming – BEPS Pillar One MLC on track for signature in June.
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