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 – 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.