The latest edition of Tax News: Investing in the USA is attached below. Prepared by Ernst & Young's International Tax Services group, this communication summarizes recent international tax developments in the United States pertinent to multinational companies based outside the United States. Highlights of this edition include:

Legislation

— Extenders/omnibus passed and signed into law
— US Senate Foreign Relations Committee approves tax agreements; further Senate action uncertain
— House, Senate committees hold hearings on BEPS, EU state aid and inversions
— Treasury grants yet another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts

Treasury news

— US CbC reporting regulations released on 21 December
— House bill would impose requirements on CbC collection and transmission
— US to participate in drafting OECD BEPS multilateral instrument; new US Model Treaty expected early in 2016
— Section 871(m) ELI effective date officially delayed

IRS and FATCA news

— More countries engaging in US automatic exchange of information
— IRS upgrades FATCA online registration system
— IRS to target inbound middle market companies for exam; US-India APA applications being accepted in 2016

Treaty rates

— Treaty withholding tax rates

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