A review of the week's major US international tax-related news. In this edition: US threatens retaliation against France's new DST – IRS begins sending virtual currency letters to taxpayers

A review of the week's major US international tax-related news. In this edition: Altera Corp. files petition for rehearing challenge of 2003 cost sharing regs – IRS publishes final regs relating to the allocation of creditable foreign tax expenditures by a partnership – UK's Boris Johnson to succeed Theresa May as Prime Minister; UK publishes draft legislation and consultation paper on EU MDR – OECD updates peer review of preferential tax regimes

A review of the week's major US international tax-related news. In this edition: US Senate approves four protocols updating the existing bilateral tax treaties with Luxembourg, Switzerland, Japan and Spain – IRS releases additional information to assist with filing and payment obligations for Section 965 transition tax on untaxed foreign earnings – G7 Finance Ministers support OECD two-pillar project to develop new rules for taxing multinational businesses – 2019 UN tax treaty negotiation manual updated to reflect changes in 2017 UN Model Treaty – APMA's functional cost diagnostic model intended to help officials with complex cases

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US government initiates review of France's new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee reports out 4 tax protocols to full Senate – US Senate Finance Committee leaders urge Treasury to intensify efforts to convince France not to enact DST – IRS official says proposed GILTI regulations' "high taxed exclusion" prospective date meant to assess election's operation

A review of the week's major US international tax-related news. In this edition: US Senate Foreign Relations Committee to vote on protocols to US tax treaties with Switzerland, Luxembourg, Spain, and Japan on 25 June 2019 – US releases final GILTI regulations – IRS temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules – Ninth Circuit reverses US Tax Court in Altera v. Commissioner – US, Cyprus negotiating CA agreement to exchange CbC reports

A review of the week's major US international tax-related news: US Senate may hold long-delayed tax treaty hearing – G20 finance ministers approve OECD's digital work plan – DC Circuit affirms Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co. SA – Final GILTI regulations due out before 22 June 2019.

A review of the week's major US international tax-related news: OMB completes review of final and proposed GILTI regulations; Treasury to release before 22 June – US participation exemption guidance clears OMB review – IRS issues proposed regulations on exception from tax for foreign pension fund interests in US real property – IRS LB&I withdraws RAB Share Directive for cost sharing arrangements.

A review of the week's major US international tax-related news: OECD releases digital taxation work program – OMB sets December 2019 target date for release of many high-profile international TCJA final regulations – IRS Commissioner says cryptocurrency guidance coming within 30 days – TIGTA issues report on IRS implementation of Section 965 deemed repatriation tax