Episodes
A review of the week's major US international tax-related news. In this edition:
OECD will release two more rounds of BEPS Pillar Two GloBE administrative guidance – US will not sign Pillar One MLC until India and China agree to unresolved transfer pricing issues.
Published 05/31/24
A review of the week's major US international tax-related news. In this edition:
US House Ways & Means Committee launches new TCJA public comment portal – US opposes annual billionaire global wealth tax proposal – IRS notice extends Section 871(m) transition relief for dividend equivalent transactions – IRS to defer applicability date of some provisions in Sections 59A and 6038A regs for qualified derivative payments – Section 6045 final crypto reporting regulations coming in 2024 – OECD...
Published 05/23/24
A review of the week's major US international tax-related news. In this edition:
US Senate Finance Committee Chair working with Majority Leader to bring tax bill to Senate floor – CBO releases new revenue estimate on TCJA extension – White House National Economic Advisor offers insights into Biden Administration tax policy
Published 05/17/24
A review of the week's major US international tax-related news. In this edition:
US Ways and Means Chairman says all current TCJA measures will be on the table in 2025 – Treasury official says proposed regulations on CAMT in advanced stage.
Published 05/10/24
A review of the week's major US international tax-related news. In this edition:
US House Ways and Means Committee hearing highlighted expiring TCJA, OECD BEPS – IRS updates rules for requesting PLRs on Section 355 transactions.
Published 05/06/24
A review of the week's major US international tax-related news. In this edition:
US tax policy lines being drawn ahead of 2024 election, TCJA ‘cliff’ – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – OECD releases consolidated GloBE commentary document, revised GloBE examples.
Published 04/26/24
A review of the week's major US international tax-related news. In this edition:
IRS waives penalty for failure to pay estimated CAMT – OECD BEPS 2.0 update: what’s coming – IESBA announces changes to its Tax Planning and Related Services project that will apply to all tax planning activities.
Published 04/19/24
A review of the week's major US international tax-related news. In this edition:
IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One Multilateral Convention on Amount A moving forward.
Published 04/12/24
A review of the week's major US international tax-related news. In this edition:
US Congress returns from spring recess; no movement on tax bill – IRS releases latest APA report – OECD misses deadline on BEPS Pillar One MLC on Amount A.
Published 04/05/24
A review of the week's major US international tax-related news. In this edition:
US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.
Published 03/29/24
A review of the week's major US international tax-related news. In this edition:
Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.
Published 03/22/24
A review of the week's major US international tax-related news. In this edition:
President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.
Published 03/15/24
A review of the week's major US international tax-related news. In this edition:
President Biden delivers State of the Union address, offers new tax proposals – US House Ways & Means Tax Subcommittee holds hearing on OECD BEPS Pillar 1 – OECD Secretary-General Tax Report offers insights on BEPS project.
Published 03/08/24
A review of the week's major US international tax-related news. In this edition:
US IRS exempts Form 1042 electronic filing in 2024 for US and nonresident withholding agents – IRS will no longer issue significant single issue PLRs – US Senate approves nomination of new IRS Chief Counsel – EY launches new tax podcast series.
Published 03/01/24
A review of the week's major US international tax-related news. In this edition:
US Congress to return to session – OECD releases final guidance on BEPS Pillar One Amount B on baseline distributions.
Published 02/23/24
A review of the week's major US international tax-related news. In this edition:
US House and Senate recess; focus to turn to approaching government funding deadlines, tax package possible – IRS sending info request letters to US-based subsidiaries of foreign-owned corporations re intercompany transaction pricing – IRS plans to finalize proposed FX regulations by year-end – US signs extension to moratorium agreement on unilateral measures, including DSTs.
Published 02/16/24
A review of the week's major US international tax-related news. In this edition:
US House-passed tax package may require Senate Finance Committee markup – Senate begins two-week recess.
Published 02/09/24
A review of the week's major US international tax-related news. In this edition:
US House of Representatives passes tax package; Senate action unclear – IRS expects to finalize two sets of Section 367 proposed regulations in first half of 2024 – Senate Finance Committee again approves IRS Chief Counsel nomination – OECD releases first statistics on ICAP.
Published 02/02/24
A review of the week's major US international tax-related news. In this edition:
US tax package may get House floor vote week of 29 January, future in the Senate uncertain – US officials offer international tax regulatory update on CAMT, stock buyback excise tax, cloud computing and PTEP rules – OECD releases working paper on global minimum tax and taxation of MNE profit.
Published 01/26/24
A review of the week's major US international tax-related news. In this edition:
House and Senate tax writers release $78 billion tax package – Congress passes CR to fund the government – IRS announces cryptocurrency transactions do not have to be reported until regulations issued.
Published 01/19/24
A review of the week's major US international tax-related news. In this edition:
US Congress returns from recess, government spending and possible tax package on the agenda – IRS to release CAMT package shortly – Treasury official offers US position on BEPS Pillar One – OECD Working Paper addresses global minimum tax and MNE taxation – EY releases 2024 International Tax and Transfer Pricing Survey, respondents say BEPS 2.0 project expands risk of double taxation.
Published 01/12/24
A review of the week's major US international tax-related news. In this edition:
US-Hungary tax treaty ceased to have effect – IRS issues interim guidance on basis adjustments re: inbound liquidations or asset reorganizations – IRS updates list of treaty partner countries – IRS broadens scope of possible private letter rulings.
Published 01/05/24
A review of the week's major US international tax-related news. In this edition:
OECD/G20 Inclusive Framework releases BEPS 2.0 Pillar Two Administrative Guidance on GloBE rules – OECD announces new BEPS Pillar One MLC timeline – US-Chile income tax treaty enters into force – US Congress adjourns until January 2024 – Congressional JCT releases Bluebook on tax legislation in 117th Congress.
Published 12/22/23
A review of the week's major US international tax-related news. In this edition:
US Treasury and IRS issue FTC guidance addressing BEPS 2.0 Pillar Two GloBE top-up taxes – IRS CAMT regs delayed to 2024, but CAMT Notice released – IRS announces active compliance campaign on CAMT – Stock buyback excise tax guidance still on track for 2023 release – IRS official says PTEP targeted notice coming soon – US government plans to finalize foreign government investment exemption regs in 2024 – IRS...
Published 12/15/23
A review of the week's major US international tax-related news. In this edition:
US Supreme Court holds oral arguments in Moore transition tax case – Congress set to adjourn next week.
Published 12/08/23