Explore every episode of the podcast EY Cross-Border Taxation Alerts

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

US government shutdown continues amid talks – IRS releases FAQs on digital asset transaction reporting by brokers – President Trump signs two EOs on trade with China – US Supreme Court holds oral arguments in critical tariff case – OECD releases MAP and APA stats on 'Tax Certainty Day."

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

US government shutdown continues, pressure building – Treasury on track to release OBBBA international guidance by year-end – Congressional leaders warn of retaliatory action if France passes DST legislation – US announces trade Framework Agreements with Malaysia, Cambodia, Thailand and Vietnam.

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

US Congress returns following August recess to address FY 26 budget deadline, possible second reconciliation bill – Canada reduces retaliatory tariffs on US goods – US ups tariff rate on India to 50%.

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

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

Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

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

US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and "promoters abusing tax rules on the books." 

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

US announces plans for proposed rules on transfer of US real property interests – US issues notice on proposed removal of final DPL rules – IRS announces CAP application period for 2026 – President Trump announces framework for US-EU trade negotiations – Tax press reporting on draft OECD document on possible changes to BEPS Pillar Two global minimum tax.

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

US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

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

US Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.

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

IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

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

Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

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

Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

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

US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.

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

OECD releases BEPS 2.0 Pillars One and Two technical documents – House Ways and Means Tax Subcommittee hearing on BEPS sees Republicans criticize Biden Administration's policy – IRS PTEP proposed regs on track for release later this year.

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

OECD releases outcome statement on BEPS 2.0 Pillars One and Two progress – US Congress considering action on a US-Taiwan tax agreement – US senators reissue crypto-assets legislative proposal, request more information – Joint Committee on Taxation issues digital asset report.

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

US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.

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

US Senate approves US-Chile income tax treaty – Congressional Joint Committee on Taxation releases revenue analysis of BEPS Pillar Two global minimum tax – BEPS Pillar One and Pillar Two developments expected in coming weeks.

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

US IRS Commissioner being replaced by dual role Treasury Secretary – US extends suspension of higher tariffs on China to 10 November – Australia High Court rules in Pepsico royalty withholding, DPT case – UN Committee wraps up August meetings on Framework Convention on International Tax Cooperation.

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

US House Ways and Means Committee approves three separate tax packages – Proposed US-Chile income tax treaty may have final US Senate vote as early as 21 June – OMB's OIRA will no longer review Treasury tax regulations – OECD officials comment on BEPS Pillars One and Two.  

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

Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.  

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

US Congress passes debt ceiling legislation – US House Ways and Means Committee Republicans introduce legislation targeting OECD BEPS 2.0 Pillar Two Undertaxed Profits Rule – US Senate Foreign Relations Committee reports out proposed US-Chile income tax treaty – US House members introduce resolution calling for legislation to prevent US-Taiwan double taxation.  

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

US House Republicans to introduce anti-BEPS Pillar Two legislation – G-7 Finance Ministers welcome OECD progress report, reiterate commitment to BEPS Pillars One and Two – IRS to hire additional transfer pricing and competent authority staff, will expand CAP, APA and pre-filing programs.

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

OECD official offers insights on BEPS Pillar One and Pillar Two – US Senate Foreign Relations Committee may act on proposed US-Chile tax treaty – IRS official clarifies coming PTEP regulations in regard to partnerships.

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

President Biden, congressional leaders in debt ceiling talks, but no breakthroughs yet – US Senate Finance Committee holds hearing on cross-border pharma manufacturers and US international tax policy – US government officials discuss CAMT guidance, another notice coming – New US-Israel tax treaty in the works – US, Swiss tax protocol negotiations progressing.

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

IRS releases proposed regulations on IP repatriation subject to Section 367(d) – Bipartisan US senators introduce bill to authorize negotiations with Taiwan to conclude tax agreement – US, Norway conducting tax treaty negotiations.

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

US House passes debt ceiling, spending bill – Treasury says no decision on interim CAMT guidance – IRS updates crypto notice – OECD to release BEPS Pillar Two qualified domestic minimum top-up tax safe harbor by summer.

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

US Congressional Republicans introduce debt limit, spending bill – SEC Chairman defends agency's authority over cryptocurrency products.

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

US Congress returns from recess; will need to address debt ceiling and spending – IRS issues proposed rules on micro-captive transactions as listed transactions.

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

US Congress enters August recess; government funding necessary, speculation about a fall tax bill – New US tariff policy in force – US imposes additional tariffs on India. 

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

IRS will provide transition period for documentation requirements for FTC "single-country exception" – US Tax Court rules IRS lacks authority to assess penalties under Section 6038(b) – US, Germany sign competent authority arrangement on automatic exchange of CbC reports.

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

OECD official expects agreement on Amount B of BEPS Pillar One by middle of 2023 – IRS releases 24th annual APA report – House Republican tax writers seek to defund US' OECD contribution.

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

IRS issues guidance on treatment of nonfungible tokens as collectibles, requests comments – US Treasury official says IF unlikely to craft BEPS Pillar Two GloBE permanent safe harbor.

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

US Treasury Secretary testifies before Senate Finance Committee on FY '24 budget; Republican members voice concern over BEPS 2.0 negotiations – Turkish Lira's hyperinflationary status has US tax consequences.

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

Biden Administration releases FY 2024 Budget and Treasury Greenbook – US officials provide updates on important regulatory developments – Senate approves Daniel Werfel as next IRS Commissioner.

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

US Supreme Court rules FBAR penalties apply per filing, not per account – IRS concludes payments from US depository institution to foreign corporation are US source subject to US withholding – OECD hopes to finalize BEPS Multilateral Convention by mid-2023.

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

IRS will issue initial guidance on how far back to apply basis adjustments to arrive at "opening" books for new CAMT – IRS releases final regulations that amend electronic filing rules for certain returns following Taxpayer First Act – IRS finalizes regulations to treat consolidated group members as single US shareholder for Section 951(a)(2)(B) purposes.

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

IRS will not release proposed PTEP regulations until latter half of 2023 – Democratic Senate Finance Committee members introduce bill to quadruple stock buyback excise tax – US-Chile tax treaty stalls in Congress.

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

President Biden gives State of the Union address to Congress; calls for quadrupling corporate stock buyback tax, 'billionaire surtax' – Senate Finance Committee announces hearing on IRS Commissioner – House Ways and Means Committee chairman addresses BEPS 2.0 to OECD Secretary-General – IRS updating guidance on APAs, competent authority assistance.

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

OECD Inclusive Framework releases Administrative Guidance under BEPS Pillar Two GloBE rules – OECD issues Manual on MAP procedures and APAs – OECD publishes package on tax dispute resolution.

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

US Congressional Republicans want second budget reconciliation bill in the fall – IRS issues interim CAMT guidance for partnerships – President Trump announces new tariff regime, major trade deals – White House releases comprehensive digital asset framework report – OECD releases XML Schemas and User guides on global minimum tax and CARF. 

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

US Congressional Joint Committee on Taxation to release Blue Book on enacted tax legislation in 117th Congress – US officials comment on cloud computing tax regulations – US considering how to implement OECD Crypto-Asset Reporting Framework – IRS announces Section 956 subpart F cash pooling campaign no longer active.

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

US-Hungary tax treaty is terminated – IRS concludes cryptocurrency worth less than a penny per unit is not a deductible Section 165 worthless loss – OECD announces new head of Centre for Tax Policy and Administration.

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

Rep. Kevin McCarthy new House Speaker, Rep. Joshua Smith named chairman of House Ways and Means Committee – IRS CAMT guidance addresses questions, leaves open issues.