Ernst & Young ITTS Washington Dispatch

A monthly review of US international tax-related developments. In this edition:

IRS proposed FTC regulations offer relief from cost recovery and source-based attribution rules, other key changes – IRS moving forward on cryptoasset issues – Section 367(d) regs coming early next year, IRS official says – No delay or transition period for final Section 1446(f) regs implementation date – Congressional Republicans urge Biden Administration to not terminate US-Hungary treaty – IRS will consider applying economic substance doctrine and related penalties more frequently in transfer pricing audits – US House Republicans seek retention of BEPS Pillar One documents and communications – OECD updates guidance on implementation of CbC Reporting.

A monthly review of US international tax-related developments. In this edition:

Proposed US FTC regs release expected soon, PTEP regs in first half of 2023 – US Treasury official says proposed crypto regs before year end – IRS may be more selective on APAs given availability of ICAP in transfer pricing disputes – IRS to reconsider APA revenue procedure guidance – Treasury developing measures for future treaties to address new tax regimes, new US-Croatia treaty before year end – G20 Finance Ministers welcome progress on BEPS 2.0, call for swift implementation – OECD releases public consultation document on administration and tax certainty aspects of Amount A of Pillar One – OECD releases report on interaction of Tax Incentives and Pillar Two – OECD/G20 Inclusive Framework holds 14th plenary meeting, publishes 6th annual progress report.

A monthly review of US international tax-related developments. In this edition:

US tax treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates – IRS PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year – Proposed IRS regulations coming on application of noncompulsory payment regs to certain amended Puerto Rico tax decrees – IRS Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation – Sixth Circuit rules in favor of Eaton Corporation in APA cancellation – OECD holds public consultation meeting on Progress Report on Amount A of BEPS Pillar One – OECD issues bilateral APA manual – OECD's Pascal Saint Amans announces plans to retire.

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 announces delay in effective date of Section 871(m) regulations – IRS Notice 2022-36 penalty relief applies to certain international tax information returns – US Tax Court increases Medtronic royalty rate under unspecified TP method – Increased IRS funding from Inflation Reduction Act may increase transfer pricing scrutiny – OECD releases 2022 update on peer review of preferential tax regimes and no or only nominal tax jurisdictions.

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 regulations – IRS proposed regulations would limit Section 1256 mark-to-market accounting for FX contracts to FX forward contracts – Treasury announces termination of tax treaty with Hungary – OECD releases Progress Report on Amount A of Pillar One of BEPS 2.0 project – G20 Finance Ministers reiterate commitment to BEPS 2.0 two-pillar implementation.

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 forthcoming BEAT regulations – IRS to expand transfer pricing audit coverage – OECD officials offer update on BEPS 2.0 Pillars One and Two – OECD releases public consultation docs on tax certainty under Amount A for Pillar One.

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 'deferred compensation expense' for FDII deductions – Changes to QI withholding agreement rules expand QI W/H and reporting responsibilities – OECD officials offer BEPS 2.0 update – OECD issues recommendations to strengthen tax administrations' cooperation re international rules, including BEPS 2.0 – OECD releases public consultation on Regulated Financial Services Exclusion under Amount A for Pillar One.

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 2021 – New Schedules K-2 and K-3 FAQs released – OECD holds public consultation on Implementation Framework for Pillar Two GloBE Rules – OECD releases public consultation document on draft rules re scope under Amount A for BEPS Pillar One – OECD releases public consultation document on Extractives Exclusion under Amount A for Pillar One – OECD releases peer review reports on dispute resolution – OECD releases fourth annual peer review report on BEPS Action 6 on prevention of treaty abuse.

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, Belarus – Final FTC regulations will be revisited to address BEPS 2.0 Pillar Two rules – Proposed PTEP regulations coming second half of 2022 – Senate Foreign Relations Committee reports out proposed US-Chile tax treaty – OECD releases Commentary and illustrative examples on Pillar Two Model Rules.

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 transition relief – Treasury official briefs Senators on future cryptocurrency reporting regs – OECD releases BEPS 2.0 Pillar One public consultation on draft nexus and revenue sourcing rules – OECD releases Pillar One public consultation on draft rules for tax base determinations – OECD finalizing crypto reporting framework.