EY Cross-Border Taxation Alerts

de Dan Palkowski

The EY Cross-Border Taxation Podcast series brings you the latest developments in major international tax news from around the globe.

Episodios

EY Cross-Border Taxation Spotlight for Week ending 18 January 2019

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS releases final Section 965 transition tax regulations – US Senate Finance Committee’s first priority is tax extenders legislation

EY Cross-Border Taxation Spotlight for Week ending 11 January 2019

por Dan Palkowski

New House Ways and Means Committee Chairman offers hints re: tax agenda – IRS issues final Section 163(j) Form and Instructions

EY Cross-Border Taxation Spotlight for Week ending 04 January 2019

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US Congress fails to enact year-end tax legislation, Federal government enters into partial shutdown – Outgoing House Ways and Means Committee Chairman releases discussion draft of Tax Technical and Clerical Corrections Act – Status of OMB review of TCJA regulations during government shutdown unclear

EY Cross-Border Taxation Spotlight for Week ending 21 December 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House approves tax bill; Senate action unlikely -- Congressional Joint Committee on Taxation releases general explanation of the Tax Cuts and Jobs Act (Blue Book) – IRS issues proposed regulations on Sections 245A(e) and 267A – IRS issues proposed regulations under Section 864(c)(8) on tax treatment of foreign partners gains on sale of a US partnership interest – IRS Notice 2019-01 announces future regulations re: foreign corporations with PTEP -- OMB received proposed Section 250 regulations for review

EY Cross-Border Taxation Spotlight for Week ending 14 December 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House tax leader releases modified year-end tax package -- IRS releases proposed Section 59A Base Erosion and Anti-Abuse Tax (BEAT) regulations – IRS issues Section 965 transition tax FAQs -- OMB completes review of proposed TCJA Section 864c()(8) regulations; release imminent – IRS issues proposed FATCA, withholding regulations – US Treasury issues another FBAR extension -- OECD will release major digital tax update end of January 2019

EY Cross-Border Taxation Spotlight for Week ending 07 December 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US Republican efforts to move tax legislation stall in House – US Treasury sends final Section 965 transition tax regulations, proposed regulations under Section 864(c)(8) to OMB for review – ECOFIN fails to reach agreement on proposed EU Digital Services Tax; US House tax leader weighs in

EY Cross-Border Taxation Spotlight for Week ending 30 November 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on computing interest expense limitation under Code Section 163(j) – IRS releases complex foreign tax credit regulations – Congressional Republicans advance year-end tax legislation in lame-duck session

EY Cross-Border Taxation Spotlight for Week ending 23 November 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US, Singapore signed TIEA and new FATCA Model I IGA – OECD released update to 2017 Progress report on Preferential Tax Regimes – OECD Inclusive Framework on BEPS released substantial activities requirement for “no or only nominal tax” jurisdictions -- OECD now gathering input on implementation of BEPS Action 14 minimum standard for review of seventh batch of jurisdictions

EY Cross-Border Taxation Spotlight for Week ending 16 November 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance – US House tax leader eying 70-80 TCJA technical corrections for lame-duck legislation

EY Cross-Border Taxation Spotlight for Week ending 09 November 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US mid-term election will affect tax in Congressional lame-duck and 2019 – Treasury sends TCJA’s BEAT and FTC proposed regulations to OMB for review -- EU Ministers meet on proposed Digital Services Tax

EY Cross-Border Taxation Spotlight for Week ending 02 November 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS recently issued Section 163(j) draft Form 8990, draft instructions for BEAT Form 8991 – IRS LB&I issues 3 more international tax compliance campaigns -- US House tax leader issues warning about proposed UK DST, other unilateral measures – Netherlands announces intent to repeal Decree re: US-Netherlands tax treaty relation to hybrid entities

EY Cross-Border Taxation Spotlight for Week ending 26 October 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existing tax treaty

EY Cross-Border Taxation Spotlight for Week ending 19 October 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: Proposed FTC and Section 163(j) regulations release to OMB Office of Regulatory Affairs imminent -- Proposed PTI regulations unlikely to be released as complete package by year-end – 2018 IRS deadline for QI, Withholding Foreign Partnership and Withholding Foreign Trust applications is 16 November 2018 – OECD making progress on digital tax framework

EY Cross-Border Taxation Spotlight for Week ending 12 October 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA’s FDII later this month -- US official says OECD making good progress on long-term digital tax package

EY Cross-Border Taxation Spotlight for Week ending 05 October 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS Notice 2018-78 provides welcome amendments to Section 965 proposed regulations – IRS proposed regulations on GILTI to be published in Federal Register on 10 October 2018; 60-day comment period begins

EY Cross-Border Taxation Spotlight for Week ending 28 September 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House moves forward with ‘tax reform 2.0’ – GILTI regulations to be finalized by June 2019 – IRS restructuring Advance Pricing and Mutual Agreement program.

EY Cross-Border Taxation Spotlight for Week ending 21 September 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations removing IRC Section 385 debt/equity documentation regulations – IRS releases draft Form 8991 on new Section 59A BEAT provision -- IRS Notice 2018-72 delays effective date of Section 871(m) dividend equivalent payments by two years – US House tax leader urges IRS to issue virtual currency guidance – OECD issues additional CbCR guidance.

EY Cross-Border Taxation Spotlight for Week ending 14 September 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 951A GILTI regulations – IRS issues guidance on REIT Section 951A, foreign currency income inclusions – House tax writing committee approves Tax Reform 2.0

EY Cross-Border Taxation Spotlight for Week ending 07 September 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-election session – House tax-writing committee to move Tax Reform 2.0 week of 10 September

EY Cross-Border Taxation Spotlight for Week ending 31 August 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: OECD released fourth round of BEPS Action 14 peer reports on improving tax dispute resolution mechanisms.

EY Cross-Border Taxation Spotlight for Week ending 24 August 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US Treasury sends TCJA’s global intangible low taxed income (GILTI) regulations to OMB for review – IRS issues draft forms for GILTI, foreign derived intangible income (FDII) provisions

EY Cross-Border Taxation Spotlight for Week ending 17 August 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: Second Circuit Court of Appeals affirms district court decision in Trusted Media Brands, Inc. v. USA -- Eighth Circuit Court of Appeals vacates 2017 Tax Court order in Medtronic, Inc. v. Comm’r

EY Cross-Border Taxation Spotlight for Week ending 10 August 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition:US Ninth Circuit withdraws opinion in Altera – US Tax Court rules partnership’s Section 1446 withholding tax liability is a partnership item – Congressional Republicans urge President Trump to nominate OECD ambassador

EY Cross-Border Taxation Spotlight for Week ending 03 August 2018

por Dan Palkowski

IRS releases Section 965 proposed regulations on TCJA repatriation transition tax -- Ninth Circuit reverses Tax Court in Altera cost sharing case – DC Circuit overturns Tax Court in Good Fortune Shipping, rules Section 883 ‘”bearer share” regulations invalid -- IRS FATCA certification portal is now live

EY Cross-Border Taxation Spotlight for Week ending 27 July 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House tax leader releases Tax Reform 2.0 framework – OMB completes review of Proposed Section 965 transition regulations – OECD Secretary-General Report to G20 Finance Ministers and Central Bank Governors on BEPS, tax transparency released

EY Cross-Border Taxation Spotlight for Week ending 20 July 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House Republicans to release outline of proposals for “phrase 2” tax reform bill week of 23 July 2018 – OMB review of proposed Section 965 repatriation transition regulations pending -- Treasury official offers insights into coming TCJA international tax guidance – IRS official say countries reviewing how to use CbC reporting data

EY Cross-Border Taxation Spotlight for Week ending 13 July 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US international-focused tax technical corrections bill expected following November elections – Tax Reform 2.0 may fine-tune new international provisions – IRS issues final anti-corporate inversion regulations – IRS LB&I announces two new compliance campaigns on repatriation of foreign earnings -- IRS LB&I issues transfer pricing, automatic exchange of information memos – US Treasury Inspector General for Tax Administration releases negative FATCA report – OECD issues discussion draft on financial transactions under BEPS Actions 8-10

EY Cross-Border Taxation Spotlight for Week ending 29 June 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition:US House Ways and Means Committee Chairman Kevin Brady discusses tax reform 2.0 – IRS to issue new proposed rules this year for controlled foreign corporations’ previously taxed income – proposed regulations withdrawing the Section 385 debt-equity documentation rules officially “pending review” – OECD Multilateral Convention to enter into force on 1 July 2018 – OECD announces publication of stakeholder comments it received in response to request for public comments on revisions to OECD Transfer Pricing Guidelines – OECD launches comparable tax revenue database

EY Cross-Border Taxation Spotlight for Week ending 22 June 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition:US Supreme Court rules in South Dakota v. Wayfair; major impact on all companies with sales to US, including foreign-based companies – US House Budget Committee approves FY 2019 budget resolution -- OECD releases two reports, on Hard-to-Value Intangibles and application of Transactional Profit Split Method

EY Cross-Border Taxation Spotlight for Week ending 15 June 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US congressional tax leader wants ‘phase 2’ reform bill released before August recess – IRS announces plan to delay application of Section 987 FX regulations for additional year -- IRS will give US W/H agents 60 days following issuance of IDR to cure accounts – IRS soon to release final FATCA regulations for FFI ‘sponsors’ – IRS will issue two sets of guidance for TCJA’s new Section 1446(f)

EY Cross-Border Taxation Spotlight for Week ending 08 June 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: IRS announces Section 965 transition late-payment penalty and filing relief -- US officials offer more insights on upcoming international TCJA guidance – US taxpayers with high-risk transfer pricing and PE issues that participate in OECD’s ICAP may face IRS exam – IRS to deploy portal for FATCA certifications by late July, early August

EY Cross-Border Taxation Spotlight for Week ending 01 June 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: White House official confirms ‘phase 2’ tax reform discussions with Congressional tax writers – US, Croatia considering tax treaty – OECD issues first peer report on BEPS Action 13 -- EU Council adopts Directive on new mandatory reporting of cross-border reportable arrangements.

EY Cross-Border Taxation Spotlight for Week ending 25 May 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US House Republicans, Trump Administration discussing framework for ‘phase two’ tax reform -- Final anti-corporate inversion regulations may be out in June -- IRS LB&I reviewing ongoing compliance campaigns in light of TCJA -- Updated UN Model Tax Treaty released.

EY Cross-Border Taxation Spotlight for Week ending 18 May 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: Acting IRS Commissioner talks at May 2018 ABA Section of Taxation meeting about guidance projects implementing the TCJA – Treasury and IRS officials also address several tax reform related issues at the Meeting – IRS official reports IRS considering whether potential regulations under Section 267A should prevent the denial of deductions when a hybrid instrument or entity is not the cause of preferential treatment of relevant income – US District Court dismisses taxpayer’s suit against IRS in transfer pricing dispute.

EY Cross-Border Taxation Spotlight for Week ending 11 May 2018

por Dan Palkowski

A review of the week's major US international tax-related news. In this edition: US OMB Office of Regulatory Affairs provides insight into scope and release of TCJA international tax regulations – US House Ways and Means Committee to hold hearings on economic effects of tax reform – IRS announces plans to issue regulations expanding exception to Section 956(c) US property -- OECD considering revising Transfer Pricing Guidelines.