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Ernst & Young's U.S. Tax This Week newsletter for the week ending September 11 is now available. Prepared by Ernst & Young's National Tax Department in Washington, D.C., this weekly update summarizes important news, cases, and other developments in U.S. taxation.

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EY Guides, Surveys, and Reports

EY's 2019-20 Worldwide Transfer Pricing Guide now available
The EY Worldwide Transfer Pricing Reference Guide 2019-20, is a publication designed to help international tax executives identify transfer pricing rules, practices and approaches. These must be understood for a company to carry out both transfer pricing compliance and planning activities in the base erosion and profit shifting (BEPS) era. The information included in the EY Worldwide Transfer Pricing Global Reference Guide 2019-20 covers 134 jurisdictions. It is meant to provide an overview for the covered jurisdictions regarding their transfer pricing tax laws, regulations and rulings; Organisation for Economic Co-operation and Development (OECD) Guidelines treatment; documentation requirements; transfer pricing returns and related-party disclosures; transfer pricing documentation and disclosure timelines; BEPS Action 13 requirements; transfer pricing methods; benchmarking requirements; transfer pricing penalties and relief from penalties; statutes of limitations on transfer pricing assessments; likelihood of transfer pricing scrutiny and related audits by the tax authorities; and opportunities for advance pricing agreements (APAs).

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Upcoming Webcasts

Work from anywhere: How to manage implications of workforce transformation (September 15)
During this Thought Center Webcast, Ernst & Young professionals will discuss the latest developments, share market insights, and break down pertinent issues to consider in managing the challenges and embracing the opportunities.

International tax talk quarterly series with the EY Global Tax Desk Network (September 15)
In an environment defined by continuous global change and shifting paradigms, multinationals are having to evaluate their global supply chains. COVID-19 supply interruptions, trade policy uncertainty, the evolving geopolitical landscape, and increasing customer and consumer demands are creating new risks. During this Thought Center Webcast, Ernst & Young professionals will discuss how organizations can address these business challenges and manage their global tax profile amid disruption, with a focus on ASEAN and India.

Supporting a Safe Return to Work with EY ServiceNow (September 15)
During this Thought Center Webcast, Ernst & Young professionals from EY People Advisory Services, the EY-ServiceNow Alliance team and ServiceNow will discuss how companies can plan, manage and execute a safe physical return to work in the wake of the COVID-19 pandemic.

Tax Tech Power Platform webcast series: Getting started with data and calculations (September 16)
During this Thought Center Webcast, Ernst & Young professionals will demonstrate how to conduct data collection, ingestion and perform complicated calculations on the Power Platform using the State Apportionment process as our example.

Special purpose acquisition companies (SPACs): A popular alternative path to the public markets (September 23)
During this Thought Center Webcast, Ernst & Young professionals will review the latest trends driving this rise in SPAC transactions. We’ll also cover the basics of executing a SPAC, with key perspectives from our experienced financial accounting, tax and capital markets professionals.

Accounting for income taxes: A quarterly perspective (September 29)
During this Thought Center Webcast, a panel of experienced Ernst & Young LLP professionals, moderated by Angela Evans, EY Americas Co-Director of Tax Accounting and Risk Advisory Services (TARAS), will discuss ongoing issues and regulatory trends in the tax accounting arena. Topics will include recent tax legislation with tax accounting implications and a review of current income tax accounting concepts.

Tax Tech Power Platform webcast series: Ensuring productivity through workflow and task management (September 29)
During this Thought Center Webcast, Ernst & Young professionals will leverage the outputs from session 1 and show how the Power Platform can initiate user workflow for the generation of quarterly estimated state payments that utilize the state apportionment data from session 1.

Tax Tech Power Platform webcast series: Conducting comprehensive reporting and data analytics to streamline the workflow review process (October 14)
During this Thought Center Webcast, Ernst & Young professionals will show how Power BI can be utilized to streamline the workflow reviews and signoffs of tasks from session 2 by providing analytics that highlight year over year apportionment factors, payments and workflow analytics.

Tax Tech Power Platform webcast series: Process optimization through forms/document automation and tax system integration (October 28)
During this Thought Center Webcast, Ernst & Young professionals will demonstrate how you can use the Power Platform to populate state estimated tax payment forms as well as integrate data back into tax systems for e-filings.

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Recent Tax Alerts

Internal Revenue Service

— Sep 09: IRS attorneys respond to questions about the employee Social Security tax deferral (Tax Alert 2020-2204)

— Sep 09: IRS final regulations clarify deductions related to trust funds for decommissioning nuclear power plants (Tax Alert 2020-2203)

— Sep 09: IRS releases draft 2020 Form 990-T and draft Schedule A (Form 990-T), inviting comments (Tax Alert 2020-2201)

— Sep 09: IRS issues advance copy of final IRC Section 807(f) regulations on computing life insurance reserves (Tax Alert 2020-2195)

— Sep 09: IRS issues revenue ruling illustrating when change in basis occurs under IRC Section 807(f) (Tax Alert 2020-2193)

— Sep 08: Notice 2020-69 provides rules on entity treatment election for certain S corporations for purposes of GILTI in AAA inclusions (Tax Alert 2020-2190)

— Sep 08: Executive summary on the employee Social Security tax deferral (Tax Alert 2020-2182)

— Sep 03: LB&I accepting new applicants for 2021 CAP program (Tax Alert 2020-2180)

— Sep 03: IRS issues guidance on designating issues for litigation (Tax Alert 2020-2179)

— Sep 03: Congressional Budget Office releases new federal deficit and debt projects (Tax Alert 2020-2178)

— Sep 03: IRS's new BBA partnership website gathers information and resources on centralized audit regime (Tax Alert 2020-2177)

— Sep 03: IRS releases guidance on 2020 pension plan funding relief and related tax deduction issues (Tax Alert 2020-2176)

— Sep 08: IRS issues final regulations providing nuclear decommissioning trust guidance (Tax Alert 2020-2170)

— Sep 01: IRS to issue regulations addressing S corporations with accumulated E&P (Tax Alert 2020-2161)

— Sep 01: IRS launches website for BBA centralized partnership audit regime (Tax Alert 2020-2160)

— Sep 01: Treasury and the IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules on GILTI gap period (Tax Alert 2020-2157)

— Sep 01: IRS issues guidance on employee deferral of Social Security tax (Tax Alert 2020-2149)

— Aug 28: IRS announces temporary deviation from handwritten signature requirement (Tax Alert 2020-2148)

— Aug 28: IRS issues guidance implementing Social Security tax withholding under Presidential Memorandum (Tax Alert 2020-2147)

— Sep 01: Treasury and IRS finalize DRD anti-abuse regulations with few changes (Tax Alert 2020-2142)

International

— Sep 10: EY Canada's Tax Matters @ EY for September 2020 (Tax Alert 2020-2211)

— Sep 10: PE Watch: Latest developments and trends, September 2020 (Tax Alert 2020-2210)

— Sep 09: Chile enacts new COVID-19 tax incentives package (Tax Alert 2020-2202)

— Sep 09: Cyprus' Tax Authority issues clarification note regarding bilateral CAA with US (Tax Alert 2020-2199)

— Sep 09: Cyprus and Russia sign the Protocol to amend double tax treaty (Tax Alert 2020-2198)

— Sep 09: Poland announces amendments to withholding tax reform (Tax Alert 2020-2197)

— Sep 09: Poland announces bill to amend corporate income tax rules (Tax Alert 2020-2196)

— Sep 08: Ecuador requires certain taxpayers to pay all estimated income taxes for tax year 2020 by September 11, 2020 (Tax Alert 2020-2186)

— Sep 08: UAE updates Economic Substance Regulations (Tax Alert 2020-2185)

— Sep 08: UK releases new technical guidance for manufacturers (Tax Alert 2020-2184)

— Sep 02: French Tax Authorities release new guidelines on dividend withholding tax exemption for foreign collective investment vehicles (Tax Alert 2020-2167)

— Sep 01: Japan's immigration information as of September 1 provided (Tax Alert 2020-2162)

— Aug 31: Dutch State Secretary of Finance publishes Decree on Brazilian "Interest on Net Equity" qualification (Tax Alert 2020-2156)

— Aug 31: Colombian Government issues regulations on the mega-investment special tax regime (Tax Alert 2020-2154)

— Aug 31: Kenya revises list of dutiable goods that may be warehoused in a bonded facility (Tax Alert 2020-2153)

— Aug 31: Canada announces transition plan from the Canada Emergency Response Benefit (CERB) (Tax Alert 2020-2151)

— Aug 28: Tanzania Revenue Authority introduces e-system for tax return filings (Tax Alert 2020-2144)

— Aug 28: Cyprus amends VAT law to improve tax collection and address VAT fraud (Tax Alert 2020-2143)

Legislation

— Sep 11: What to expect in Washington (September 11) (Tax Alert 2020-2218)

— Sep 10: Republicans 'targeted' pandemic relief bill fails to advance in Senate, 52-47 (Tax Alert 2020-2209)

— Sep 08: Senate Republicans plan vote on targeted COVID-19 relief (Tax Alert 2020-2189)

States

— Sep 10: Arkansas issues legal opinion on state income taxation of teleworkers (Tax Alert 2020-2207)

— Sep 09: EY survey results: Are employers participating in the employee Social Security tax deferral program? (Tax Alert 2020-2200)

— Sep 03: US unemployment rate continues to fall; more states take federal loans to fund UI benefit payouts (Tax Alert 2020-2174)

— Sep 02: Iowa extends withholding tax deadline for certain businesses and cities (Tax Alert 2020-2166)

— Sep 01: New guidance on deferring employees' FICA share raises issues for employers (Tax Alert 2020-2163)

— Sep 01: In response to COVID-19, U.S. Department of Labor explains importance of tracking work hours of teleworkers (Tax Alert 2020-2159)

— Aug 28: Ohio Appellate Court allows corporation to include all affiliated corporations in its city net profits tax consolidated return (Tax Alert 2020-2145)

— Aug 28: Michigan SUI taxable wage base expected to increase for 2021 due to COVID-19's depletion of UI trust fund (Tax Alert 2020-2141)

— Aug 28: Immediate action recommended for companies receiving letters from Delaware on voluntary disclosure agreements for unclaimed property (Tax Alert 2020-2140)

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Recent Newsletters

State and Local Tax Weekly
   Highlights of this edition include:

• Ohio Appellate Court allows corporation to include all affiliated corporations in its city net profits tax consolidated return. In its opinion in Time Warner Cable, Inc. v. Cincinnati, the Ohio Court of Appeals, First Appellate District (court) held that the taxpayer could include in its consolidated municipal net profits return all affiliated corporations that were included in its consolidated federal income tax return. In so finding, the court affirmed a decision of the Ohio Board of Tax Appeals (BTA) reversing a determination of the Cincinnati Income Tax Board of Review
• Income/Franchise, Sales & Use, Business Incentives, Property Tax, Controversy, Payroll & Employment Tax, Miscellaneous Tax, Global Trade, Value Added Tax

ITS/Washington Dispatch
   Highlights of this edition include:

Treasury and IRS news

• Treasury and IRS finalize DRD anti-abuse regulations with few changes
• Treasury and the IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules on GILTI gap period

Tax treaty news

• US, Swiss competent authorities reach agreement on treaty arbitration process

Digital Taxation

• UN tax committee issues proposal for taxing digital services income

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IRS Weekly Wrap-Up

Final Regulations

Notices

Internal Revenue Bulletin

Because the matters covered herein are complicated, U.S. 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.