taxnews.ey.comPrint

22 April 2018

U.S. International Tax This Week for the Week Ending April 20

Ernst & Young's U.S. International Tax This Week newsletter for the week ending April 20 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.

—————————————————————————
Spotlight

The European Union (EU) is continuing its deliberations on whether certain elements of US tax reform, such as the base erosion and anti-abuse tax (BEAT), the global intangible low-taxed income (GILTI) provision, and the deduction for foreign-derived intangible income (FDII), constitute preferential tax regimes or result in an unfair trade practice. The tax press this week reported that the EU Council's High Level Working Party (Taxation) was scheduled to hold a meeting on 18 April to discuss the outcome of the Organisation for Economic Co-operation and Development's (OECD's) Forum on Harmful Tax Practices (FHTP) meeting on 4 April. The OECD's FHTP meeting, initiated at the request of the EU, began its review of BEAT, GILTI, and FDII. The US reportedly presented its case on US tax reform at the FHTP meeting. The next FHTP meeting is scheduled for October, but it is unclear if any final decision by the panel will be made at that time.

Pascal Saint-Amans, Director of the OECD's Centre for Tax Policy and Administration, also commented this week on the enactment of US tax reform, during a keynote address at a European tax conference. Saint-Amans was quoted as saying that a number of the provisions in the Tax Cuts and Jobs Act appear to implement many of the outcomes of the OECD's Base Erosion and Profit Shifting (BEPS) project, a result he found somewhat surprising given what he described as the US Government's objection to the BEPS project. The OECD Director pointed to US tax reform's hybrid mismatch as an example. As far as BEAT goes, Saint-Amans characterized it as a form of rough justice that was enacted by the US as a backstop to transfer pricing rules that the US Government considers may not be up to the task of preventing base erosion and profit shifting.

—————————————————————————
Upcoming Webcasts

EU mandatory disclosure regime (April 25)
The Council of the European Union (EU) has reached agreement on a draft directive aimed at boosting transparency to tackle what it sees as aggressive cross-border tax planning. Given the breadth of the transactions and arrangements covered, relevant reporting obligations will very likely result for both companies headquartered in Europe and for non-European companies with activities in Europe. During this Thought Center Webcast, Ernst & Young professionals discuss the new provisions and how they may affect your business.

BorderCrossings … With EY transfer pricing and tax professionals (April 26)
During this Thought Center Webcast, part of an ongoing monthly series, EY transfer pricing and tax professionals will help you stay informed and able to adopt a more proactive stance in developing and defending your transfer pricing policies and practices.

International tax talk (May 8)
During this Thought Center Webcast, Ernst & Young professionals will provide you with information on major tax law changes in the countries and jurisdictions covered by our US-based Global Tax Desk Network.

—————————————————————————
Recent Tax Alerts

Africa

Asia

Canada & Latin America

Europe

Middle East

—————————————————————————
IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2018-16Internal Revenue Bulletin of April 16, 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: 2018-0855

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2025, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement