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04 March 2018

U.S. International Tax This Week for the Week Ending March 2

Ernst & Young's U.S. International Tax This Week newsletter for the week ending March 2 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.

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Spotlight

House Ways and Means Committee Chairman Kevin Brady this week said taxpayers should expect a series of small tax technical corrections bills that will address minor drafting issues in the Tax Cuts and Jobs Act (TCJA). A larger, more comprehensive technical corrections bill will take place later once the Government has had time to review the new code and stakeholders have had an opportunity to submit their comments. Chairman Brady added that international tax technical corrections will likely not happen soon.

Any technical corrections legislation will require the support of Congressional Democrats, particularly in the Senate, leaving open the question whether such support will be forthcoming.

House Ways and Means Tax Policy Subcommittee Chairman Vern Buchanan announced this week that the Subcommittee will hold a hearing on 14 March, entitled "Post Tax Reform Evaluation of Recently Expired Tax Provisions." The hearing will examine which so-called tax extenders are necessary or unnecessary following enactment of tax reform.

Dana Trier, Treasury Deputy Assistant Secretary for Tax Policy, unexpectedly resigned his post, a department official confirmed this week. Trier, who assumed his position in July 2017, has been a leading government figure in ongoing discussions regarding pending TCJA guidance. It is unclear what impact, if any, Trier's departure will have on the release of future TCJA guidance.

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Upcoming Webcasts

Global Payroll Survey Results (March 7)
Join this Thought Center Webcast for our third edition of the EY Global Payroll Survey, as we explore the changing landscape of global payroll, the challenges that are impacting your organization and the steps you can take to prepare for today's disruption.

Impact of transactions on talent in life sciences (March 12)
Transactions and consolidation continue to be a driving trend in the life sciences industry. During this Thought Center Webcast, join an esteemed group of panelists, including special guests Lisa Blair Davis, Vice President of Human Resources at Johnson & Johnson and Jonathan Zung, Group President of Clinical Development & Commercialization Services at Covance, as they share their experiences on how to maximize the potential of the transactional opportunity.

Tax administration goes digital: Preparing for a new era of digital engagement with tax administrations (April 11)
A new report from EY describes how, as a result of limited resources and increasing demands to close revenue gaps, governments around the world are ramping up their technology and analytics capabilities at a rapid pace. During this Thought Center Webcast, Ernst & Young professionals will review the report's key findings.

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Recent Tax Alerts

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Canada & Latin America

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Recent Newsletters

Washington Dispatch
   Highlights of this edition include:

Treasury and IRS news

— Treasury, IRS moving forward with TCJA international guidance; 2 more repatriation transition notices expected
— IRS guidance under new Section 965 prevents certain foreign corporations from making accounting period changes
— New guidelines issued for delinquent Forms 1120-F and waiver requests
— Treasury may delay Section 987 branch currency regulations until 2020
— IRS updates Priority Guidance Plan to add projects implementing some TCJA international provisions
— IRS assumes major role in OECD's International Compliance Assurance Program

Transfer pricing news

— IRS announces increase in user fees for unilateral and bilateral APAs

OECD developments

— OECD releases additional CbCR guidance, country approaches to CbC reporting

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2018-09Internal Revenue Bulletin of February 26, 2018

Because the matters covered herein are complicated, U.S. International Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.

Document ID: 2018-0466

 

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