EY Cross-Border Taxation Spotlight for Week ending 29 March 2024

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.