U.S. International Tax This Week for February 28

01 March 2020

Ernst & Young's U.S. International Tax This Week newsletter for the week ending February 28 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

The Office of Management and Budget's Office of Information and Regulatory Affairs (OIRA) this week completed its review of final regulations under IRC Sections 245(e) and 267A and sent them back to Treasury for final review. They joined final IRC Section 163(j) regulations on interest limitation rules which are also back at Treasury, but which reportedly will not be released until proposed regulations under IRC Section 163(j) have completed their ongoing OIRA review. Earlier in the month, a Treasury official was quoted as saying that final IRC Section 901(m) regulations would be released "any day now," but have not yet been issued.

G20 Finance Ministers met this week in Riyadh and, at the conclusion, issued a communique endorsing the Base Erosion and Profit Shifting (BEPS) 2.0 "Outline of the Architecture of a Unified Approach on Pillar One" as the basis for negotiations and welcoming progress on Pillar Two. The G20 also underscored the importance of reaching agreement on the key policy features of a digital solution by July 2020 and their commitment to reach consensus on a BEPS 2.0 final report by the end of 2020.

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Upcoming Webcasts

Countdown to MDR | Preparing for Compliance across the EU (March 3)
During this Thought Center Webcast, Ernst & Young professionals will talk about the Mandatory Disclosure Regime legislative status across the EU.

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Recent Tax Alerts

United States

— Feb 25: US Government imposes stricter export restrictions on Russia and Yemen (Tax Alert 2020-0429)

Asia

— Feb 27: South Korea advises that on-line confirmation is new process for visa approvals (Tax Alert 2020-0449)

— Feb 27: Hong Kong imposes travel ban on South Korea; Russia imposes travel ban on China (including Hong Kong) (Tax Alert 2020-0448)

— Feb 27: Hong Kong's 2020-21 Budget proposal announced (Tax Alert 2020-0447)

— Feb 24: What you need to know before Hong Kong tax year draws to a close on March 31 (Tax Alert 2020-0428)

— Feb 21: Indonesia and Singapore sign new tax treaty (Tax Alert 2020-0424)

Canada & Latin America

— Feb 27: Argentine Congress to take up bill with changes to the promotional regime for the knowledge-based economy (Tax Alert 2020-0445)

— Feb 26: Northwest Territories budget 2020-21 (Tax Alert 2020-0435)

— Feb 26: Nova Scotia budget 2020-21 (Tax Alert 2020-0434)

— Feb 25: Argentine court allows taxpayer to allocate entire negative inflation adjustment to tax year to which it corresponds (Tax Alert 2020-0433)

— Feb 24: Dominican Republic's Executive Branch enacts voluntary disclosure program and tax amnesty (Tax Alert 2020-0427)

Europe

— Feb 27: Luxembourg | Reporting implications of revised EU list of non-cooperative jurisdictions for tax purposes (Tax Alert 2020-0453)

— Feb 27: Croatia passes Law to implement Mandatory Disclosure Rules (Tax Alert 2020-0451)

— Feb 26: German Ministry of Finance publishes guidance on royalty deduction limitation rule (Tax Alert 2020-0440)

— Feb 26: Polish administrative court rules on "look-through" approach related to withholding tax on interest paid through a bank account of a Korean real estate trust (Tax Alert 2020-0439)

— Feb 26: Sweden issues final proposal on Mandatory Disclosure Rules to Parliament (Tax Alert 2020-0438)

Middle East

— Feb 21: Turkey amends Luxury Housing Tax provisions (Tax Alert 2020-0423)

Multinational

— Feb 27: OECD releases consultation document on model rules for data reporting by platform operators for sellers in the sharing economy (Tax Alert 2020-0452)

— Feb 27: OECD releases eighth batch of peer review reports on BEPS Action 14 (Tax Alert 2020-0444)

— Feb 21: OECD hosts webcast on preliminary impact assessment and economic analysis of BEPS 2.0 project proposals (Tax Alert 2020-0422)

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

2020-10

Internal Revenue Bulletin of March 2, 2020

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Additional Resources

Ernst & Young Client Portal, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

— International Tax Online Reference Service. Key information about, and important tax developments from, 56 foreign jurisdictions, including information on tax rates, interest rates and penalties, withholding, and filing dates.

— EY/Passport. EY/Passport is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

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: 2020-0457