EY Cross-Border Taxation Spotlight for Week ending 17 May 2024

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.

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 committed to open BEPS Pillar One multilateral convention for signature in June – Work continuing to finalize BEPS Pillar One Amount B provisions.

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 

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.

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.