EY Cross-Border Taxation Alerts

A review of the week's major US international tax-related news. In this edition:  Congress out of session until mid-November despite calls to reconvene and pass necessary funding measures – Upcoming election too close to predict for both presidential and congressional races – 2024 Annual Meetings of the IMF and World Bank Group to take place in Washington next week – IRS releases AM 2024-002 addressing application of Section 246(b) limitation to deductions under Sections 243, 245 and 250 – Italy and France propose changes to their digital services taxes, potentially increasing tax burdens on technology companies.

A review of the week's major US international tax-related news. In this edition:  IRS releases final IP repatriation regulations – Treasury and IRS will release technical corrections to CAMT regs – IRS final DCL regulations will clarify anti-avoidance rule – OECD issues working paper on tax arbitrage through closely held businesses.

A review of the week's major US international tax-related news. In this edition:  * US general election will have major impact on tax policy * IRS to update draft digital asset reporting instructions for Form 1099-DA * OECD issues FAQs on CARF * EY releases comprehensive analysis of proposed CAMT regs

A review of this week's major US international tax-related news. In this edition:  US presidential candidates reveal tax positions – Congress averts government shutdown with continuing resolution, adjourns until after election – US officials discuss CAMT – Digital asset noncustodial broker reporting guidance coming before year end – Puerto Rico initiates public consultation on BEPS 2.0 GloBE rules – OECD holds signing ceremony for BEPS Pillar Two Subject to Tax Rule Multilateral Instrument.

A review of this week's major US international tax-related news. In this edition:  US House Speaker promises “Day One” focus on corporate tax policy with Republican election sweep – IRS soon to release final Section 367(d) regs on IP repatriation – IRS final Section 987 FX regs to reserve on partnership issues – IRS guidance on BEPS Pillar One Amount B coming before year end – IRS official clarifies ‘disregarded payment loss’ rules effective date in recent DCL regs – IRS soon to release guidance on MAP and APA program – IRS assembling CAP transfer pricing team – OECD issues seventh annual BEPS Action 13 CbCR peer review report.