A review of the week's major US international tax-related news. In this edition:

Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.

A review of the week's major US international tax-related news. In this edition:

US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.

A review of the week's major US international tax-related news. In this edition:

US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.

A review of the week's major US international tax-related news. In this edition:

IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

A review of the week's major US international tax-related news. In this edition:

US House of Representatives chooses new speaker – US-Chile tax treaty’s reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now expected in early 2024 – Cyprus announces Cyprus-US CAA for exchange of CbC reports will be effective for RFYs starting on/after 1 January 2023 – OECD BEPS IF considering Pillar 2 guidance on treatment of deferred tax assets in countries with federal and subnational taxes

A review of the week's major US international tax-related news. In this edition:

US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce ‘U.S.-Taiwan Expedited Double Tax Relief Act’.

A review of the week's major US international tax-related news. In this edition:

OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.

A review of the week's major US international tax-related news. In this edition:

Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

A review of the week's major US international tax-related news. In this edition:

US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada’s DST proposal.

A review of the week's major US international tax-related news. In this edition:

US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer “Alternative A” in scoping rules for Amount B in BEPS Pillar One