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monthly review of US international tax-related developments. In this edition: President Biden signs Inflation Reduction Act with 15% corporate minimum tax – Inflation Reduction Act includes 1% stock buyback excise tax – Congress passes $280 billion Chips and Science Act – Applicability date for FX regs under Section 987 extended again – IRS announc…
 
monthly review of US international tax-related developments. In this edition: US Senate Majority Leader, Sen. Manchin reach agreement on $740b budget reconciliation bill with 15% corporate minimum tax – Congress passes CHIPS bill with investment tax credits and incentives – Treasury and IRS publish technical corrections to final foreign tax credit …
 
monthly review of US international tax-related developments. In this edition: Democrats fail to reach consensus on pared-down budget reconciliation package – Treasury Secretary testifies in support of anti-inflationary measures, BEPS 2.0 – US Supreme Court accepts FBAR filing case – IRS to defer reporting for certain derivative payments in forthcom…
 
monthly review of US international tax-related developments. In this edition: US budget reconciliation remains stalled, but some behind-the-scenes talks – Senators introduce Support Ukraine Through Our Tax Code Act -- More US FTC guidance coming – US officials offer international tax projects update – IRS GLAM addresses allocating/apportioning ‘def…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress returns amid speculation over limited budget reconciliation – Senate proposal would disallow FTCs, other US tax benefits connected with operations in Russia or Belarus – IRS issues annual APA report for 2…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration releases FY2023 Budget with new international tax proposals – Congress passes omnibus appropriations bill with no tax title – Senate Finance Committee Chairman supports tax sanctions for Russia, …
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Senate Democrats backburner Build Back Better, look to address inflation’s impact – G20 confirms BEPS 2.0 ambitious timeline; Republican Senators voice concerns – IRS releases FAQs on Schedules K-2 and K-3 transit…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration looks to scaled-back Build Back Better legislation – House Ways and Means Committee Republicans warn congressional consent needed for BEPS 2.0 Pillars – Final regulations released on treatment of…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration’s Build Back Better legislation stalls in Congress; Senate Finance Committee releases updated international tax provisions – Senate Foreign Relations Committee Republicans urge vote on 2010 US-Ch…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US House passes Build Back Better Act budget reconciliation bill; action moves to Senate – President Biden signs infrastructure legislation including new cryptocurrency reporting – Final FTC regs expected by year-end…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden releases pared down budget reconciliation framework – G20 leaders confirm commitment to global tax changes under BEPS 2.0 – Six country Joint Statement on transitional approach to existing unilateral …
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress fails to pass infrastructure and budget reconciliation legislation -- House Ways & Means Committee reports out reconciliation bill with major international tax proposals -- Senate Finance Committee Chairm…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US infrastructure legislation, FY 2022 budget resolution move forward – Senate Finance Committee Chairman, members release international tax discussion draft – Finance Committee Chairman introduces bill to amend tax …
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: White House, Senate negotiators reach agreement on $1.2 trillion infrastructure package – OECD announces conceptual agreement in BEPS 2.0 project; endorsed by G20 Finance Ministers, Central Bank Governors – US, UK co…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Bipartisan infrastructure deal reached, but road to passage uncertain – House passes corporate disclosure package requiring CbC tax reporting for multinationals – Biden Administration’s proposed 15% minimum tax could…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury ‘Green Book’ offers new details on international tax proposals – Senate hearing discusses Biden Administration’s international tax proposals – House bill would require SEC regulations on CbC financial inf…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury releases President’s plan to overhaul corporate tax system – US Senators release proposed International Tax Framework – President Biden lays out $1.8 trillion American Families Plan proposal – Senate Fina…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden lays out $2 trillion + infrastructure plan to be paid for with tax increases – Senate Finance Committee holds international tax hearing – Congressional Democrats introduce international tax legislation…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress poised to enact $1.9t COVID relief bill with repeal of worldwide interest expense allocation – Treasury to consider reviving expired transfer pricing aggregation regulations – IRS continues APA/MAP case closu…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary says no new taxes for now, commits to OECD BEPS discussions – New final regulations address application of Section 163(j) limitation to CFCs and partnerships, reserve on certain provisions – IRS …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax t…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Major policy changes expected following US November election – Treasury and IRS finalize regulations to reduce double taxation caused by anti-abuse rules on GILTI gap period – IRS officials provide international regul…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership i…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Final BEAT regulations adopt proposed BEAT guidance with some changes − New final and newly proposed foreign tax credit regulations released − Treasury issues final sourcing regulations on sales of personal property (…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – Treasury and IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules during GILT…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII a…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for ‘pause’ in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress considers further action to address coronavirus pandemic – IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect – Treasury and IRS announce reference…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US CARES Act stimulus package to address COVID-19 has international tax implications – IRS expands 15 April tax relief and issues FAQs on extension of filing and payment deadlines, FATCA reporting – IRS issues final S…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD issues consultation document on technical design of Pillar Two – IRS issues final regulations on ownership attribution rules for CFC purposes – IRS announces Section 965 transition tax compliance campaign – Treas…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar One ‘unified approach’ – Treasury issues final regulations removing Section 385 documentation requirements, notice of proposed rulemaking for treating some interests as debt – IRS announc…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury announces entry-into-force for protocols with Japan, Spain, Luxembourg, and Switzerland – IRS issues proposed Section 382(h) regulations on built-in gains and losses – International TJCA guidance expected …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues proposed rules on cloud-based, other digital transactions – French President Macron comments on new Digital Services Tax – IRS increase cryptocurrency enforcement efforts – IRS will allow domestic partnersh…
 
US Senate approves amending tax protocols with Luxembourg, Switzerland, Japan and Spain – US considers retaliation against France’s new DST – IRS issues proposed PFIC regulations – IRS releases final regulations for allocating partnerships’ creditable foreign tax expenditures – IRS sending warning letters to virtual currency owners – IRS issues inf…
 
Temporary and proposed DRD regulations reflect GILTI-centric view of TCJA’s international tax rules – US government issues final and proposed GILTI and subpart F regulations – IRS issues proposed regulations under Sections 954 and 958; consequences for subpart F and GILTI regimes – IRS issues proposed regulations on FIRPTA tax exception for foreign…
 
IRS releases final Section 956 regulations, generally follow proposed rules with two major modifications – IRS finalizes certain temporary FX regulations – IRS proposed regulations under Section 1446(f) clarify scope of W/H on transfers of partnership interests – EC comments on US FDII proposed regulations – US reiterates opposition to unilateral d…
 
US Congressional tax writers concerned over unilateral digital taxation proposals – IRS publishes revised 2019 Tax Treaty Table 1 – No delay in Section 965 final regulations effective date – IRS LB&I announces new compliance campaigns on transfer pricing and information reporting – IRS may use APMA FCD Model in some exams – GAO issues report on FAT…
 
OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments…
 
US Treasury official comments on OECD international tax deliberations – US supports global efforts to adopt corporate minimum tax – US government may miss June 2019 deadline to finalize TCJA international regulations – Final Section 965 regulations clarify filing Form 965-A or 965-B with transfer agreements – IRS LB&I requiring transfer pricing tea…
 
Tax agenda uncertain in new Congress -- Final IRS Section 965 transition tax regulations largely follow proposed rules, but include significant changes -- IRS releases final Form 8990 and instructions -- Argentine inflation may have US tax considerations for taxpayers with Argentine operations -- OECD releases policy note addressing tax challenges …
 
US Congress fails to enact year-end tax legislation – JCT issues ‘Blue Book’ on 2017 Tax Cuts and Jobs Act – IRS issues proposed regulations on Section 59A BEAT – IRS issues proposed regulations on foreign persons’ taxable gain on sale of partnership interestes engaged in US business -- IRS issues proposed hybrid dividends / entities regulations – …
 
Congress returns for lame-duck session; year-end tax bill taking shape – IRS releases proposed regulations and related guidance on interest expense limitation under Section 163(j) – IRS issues proposed foreign tax credit regulations – IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j) – Taxpayers told to expe…
 
Most TCJA international proposed regulations out by year-end -- IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS announces changes to Section 965 transition tax rules affecting basis election deadline, aggregate foreign cash position -- 2018 QI, W/H foreign partnership and W/H Fo…
 
US House approves ‘tax reform 2.0’ legislation – US government issues proposed GILTI regulations – Treasury and IRS propose removing Section 385 debt/equity documentation requirements -- IRS releases draft Form 8991 for TCJA’s BEAT – IRS grants relief to RICs from Section 4982 excise tax for Section 965 inclusions – IRS to delay Section 871(m) regu…
 
US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable retur…
 
US House Republicans release tax reform 2.0 framework -- IRS issues final anti-corporate inversion regulations -- Proposed repatriation transition tax regulations release imminent; Treasury official offers insights on other international projects -- IRS denies DRD to affiliated group by treating swap on stock index as SSRP regarding single issue of…
 
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