Ernst & Young ITTS Washington Dispatch

Ernst & Young ITTS Washington Dispatch

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Ernst & Young ITTS Washington Dispatch episodes

  • EY ITS Washington Dispatch, January 2019

    Tax agenda uncertain in new Congress -- Final IRS Section 965 transition tax regulations largely follow proposed rules, but include significant changes -- IRS releases final Form 8990 and instructions -- Argentine inflation may have US tax considerations for taxpayers with Argentine operations -- OECD releases policy note addressing tax challenges of digitalization -- OECD issues 2018 progress report on preferential regimes -- OECD BIAC issues tax principles for digital economy

    16 min
  • EY ITS Washington Dispatch, December 2018

    US Congress fails to enact year-end tax legislation – JCT issues 'Blue Book' on 2017 Tax Cuts and Jobs Act – IRS issues proposed regulations on Section 59A BEAT – IRS issues proposed regulations on foreign persons' taxable gain on sale of partnership interestes engaged in US business -- IRS issues proposed hybrid dividends / entities regulations – IRS announces future foreign corporate PTEP regulations – IRS issues proposed FATCA regulations – Treasury grants another FBAR extension – Puerto Rico enacts tax reform -- OECD publishes tax report to G20 leaders – OECD releases second annual peer report on BEPS Action 5

    22 min
  • ITS Washington Dispatch, November 2018
    Congress returns for lame-duck session; year-end tax bill taking shape – IRS releases proposed regulations and related guidance on interest expense limitation under Section 163(j) – IRS issues proposed foreign tax credit regulations – IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j) – Taxpayers told to expect more 'informal' guidance, including on cryptocurrencies – IRS adds four new LB&I international compliance campaigns – US, Japan sign CbCR information exchange arrangement – Netherlands to repeal decree re: US-Netherlands tax treaty regarding hybrid entities – OECD issues guidance on MLI synthesized texts, MLI entry into effect – OECD updates results on preferential tax regimes, substantial activity requirements for no/nominal tax jurisdictions – OECD begins new BEPS Action 14 minimum standard review of additional jurisdictions
    19 min
  • ITS Washington Dispatch, October 2018
    Most TCJA international proposed regulations out by year-end -- IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS announces changes to Section 965 transition tax rules affecting basis election deadline, aggregate foreign cash position -- 2018 QI, W/H foreign partnership and W/H Foreign Trust application deadline 16 November 2018 -- IRS issues guidance for REITs on certain income inclusions from foreign corps -- IRS to move on W/H tax campaigns in 2019 -- US reaffirms opposition to unilateral digital tax measures -- US, Israel to review updating tax treaty -- OECD on track for digital tax framework -- OECD releases 2017 MAP statistics
    15 min
  • ITS Washington Dispatch, September 2018
    US House approves 'tax reform 2.0' legislation – US government issues proposed GILTI regulations – Treasury and IRS propose removing Section 385 debt/equity documentation requirements -- IRS releases draft Form 8991 for TCJA's BEAT – IRS grants relief to RICs from Section 4982 excise tax for Section 965 inclusions – IRS to delay Section 871(m) regulations effective / applicability date two years – IRS issues guidance on REITS on income inclusions from foreign corporations -- IRS announces new compliance campaigns – OECR issues more CbCR guidance, updated exchange relationships
    18 min
  • ITS Washington Dispatch, August 2018
    US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable return of capital - DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations - Ninth Circuit withdraws opinion reversing Tax Court in Altera — US Tax Court rules Section 1446 W/H tax liability is a partnership item -- Eighth Circuit vacates Tax Court opinion in Medtronic, remands to Tax Court for further consideration -- OECD releases fourth batch of peer review reports on Action 14
    17 min
  • ITS Washington Dispatch, July 2018
    US House Republicans release tax reform 2.0 framework -- IRS issues final anti-corporate inversion regulations -- Proposed repatriation transition tax regulations release imminent; Treasury official offers insights on other international projects -- IRS denies DRD to affiliated group by treating swap on stock index as SSRP regarding single issue of stock -- IRS announces additional international compliance campaigns -- Treasury FATCA report finds fault with IRS -- New IRS guide on transfer pricing examinations released -- OECD releases draft on transfer pricing aspects of financial transactions -- OECD Secretary-General sends G20 finance ministers annual BEPS progress report
    19 min
  • ITS Washington Dispatch, June 2018
    US Congressional leaders talk tax reform 2.0 -- US Supreme Court overturns physical presence nexus standard; major implications for sales to the United States -- IRS updates Section 965 transition tax FAQs to include late-payment penalty, filing relief -- IRS announces additional delay of Section 987 FX regulations -- US officials offer TCJA international regulatory update -- IRS finalizing 2016 proposed FATCA regulations; portal for certifications this summer -- OECD issues guidance on hard-to-value intangibles, transactional profit split method -- OECD not in competition with EU on digital taxation, official says
    18 min
  • ITS Washington Dispatch, May 2018
    US officials offer insights, timelines on upcoming TCJA guidance -- House Republicans, Trump Administration discuss 'phase-two' tax reform -- IRS announces forthcoming regulations expanding Section 956 exception to definition of US property -- Final anti-inversion rules may be released in June – US government releases offer timing for TCJA international tax guidance -- IRS announces new template for APAs -- OECD releases first annual peer review report (Phase 1) on Action 13 -- OECD may revise Transfer Pricing Guidelines -- UN releases updated Model Tax Treaty
    15 min
  • ITS Washington Dispatch,April 2018
    Treasury, OMB announce tax regulatory review agreement – IRS notice offers some clarity on new Section 163(j) business interest expense limitation – IRS Notice 2018-26 announces anti-avoidance rules, other regulations on Section 965 transition tax – US issues CbC reporting guidance for specified national security contractors – IRS issues interim guidance under new Section 1446(f) for sales of interests in non-publicly traded partnerships – IRS considering BEAT aggregation rules as applied to control groups – IRS to release final FATCA regulations shortly – US, Indonesia sign MOU on CbC reporting – US, Costa Rica sign TIEA.
    15 min

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The Ernst & Young ITS Washington Dispatch brings you the latest developments in US tax news.