October 18, 2020 U.S. Tax This Week for October 16 Ernst & Young's U.S. Tax This Week newsletter for the week ending October 16 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.
————————————————————————— Eye on the Election (October 12) Congress on hold with election on the horizon Updated: Post-2020 tax policy possibilities | A Biden presidency and Democratic Senate could bring change to the course of tax policy ————————————————————————— State & local tax developments in the real estate industry (October 20) Latin America ‘nearshoring’ webcast series: Panama session (October 21) Tax in the time of COVID-19 (october 23) Tax Tech Power Platform webcast series: Process optimization through forms/document automation and tax system integration (October 28) ————————————————————————— Courts — Oct 15: Law firm clients: New California law allows certain nonresident aliens to elect to file group returns instead of individual returns (Tax Alert 2020-2479) Internal Revenue Service — Oct 15: Final regulations under IRC Section 1446(f) set forth rules on withholding on transfers of partnership interests (Tax Alert 2020-2481) — Oct 15: IRS says December 31 is last day for submitting Forms 1139 and 1045 by fax (Tax Alert 2020-2480) — Oct 09: IRS issues final regulations on computing and reporting life insurance reserves (Tax Alert 2020-2448) — Oct 09: Revenue ruling analyzes whether change in basis of computing life insurance reserves occurs in 10 examples (Tax Alert 2020-2447) International — Oct 15: Oman ratifies automatic exchange of information (Tax Alert 2020-2478) — Oct 15: Portuguese Government submits Draft State Budget Law for 2021 to Parliament (Tax Alert 2020-2477) — Oct 15: Egypt amends income tax and stamp duty law provisions (Tax Alert 2020-2476) — Oct 14: G20 Finance Ministers and Central Bank Governors' meeting communiqué extends mandate of Inclusive Framework to continue negotiations on BEPS 2.0 project until mid-2021 (Tax Alert 2020-2472) — Oct 14: Peruvian tax authorities address merger of nonresident entities with one entity having a PE in Peru (Tax Alert 2020-2471) — Oct 14: Ireland issues Budget for 2021: Review of indirect tax and environmental measures (Tax Alert 2020-2470) — Oct 14: Peruvian Tax Court rules Peruvian payor may not consider double tax treaty benefits when determining the withholding tax because the Certificate of Residency was issued retroactively (Tax Alert 2020-2469) — Oct 13: Saudi Arabia extends economic relief initiatives until 31 December 2020 (Tax Alert 2020-2464) — Oct 13: UK issues new guidance on Brexit and UK imports (Tax Alert 2020-2463) — Oct 13: OECD's Inclusive Framework releases BEPS 2.0 documents and agrees to continue work with target of conclusion by mid-2021 (Tax Alert 2020-2462) — Oct 12: Norway proposes 15% withholding tax on interest, royalty and certain lease payments to related parties tax resident in a low-tax jurisdiction (Tax Alert 2020-2459) — Oct 12: Argentina issues guidance on foreign exchange regulations (Tax Alert 2020-2458) — Oct 12: European Union imposes further anti-dumping duties on steel imports (Tax Alert 2020-2456) — Oct 12: European Commission requests feedback on proposed directive to transform EU's VAT Committee into a "Comitology Committee" (Tax Alert 2020-2455) — Oct 12: OECD BEPS 2.0 blueprint reports released (Tax Alert 2020-2451) — Oct 12: OECD issues reports on BEPS Pillar One and Pillar Two blueprints (Tax Alert 2020-2449) — Oct 09: Dutch Government publishes details on proposed changes to loss set-off rules (Tax Alert 2020-2444) — Oct 09: Turkey's election regarding Article 5 of the MLI may impact certain tax treaties (Tax Alert 2020-2443) — Oct 09: Kenya adjusts specific excise duty rates for inflation (Tax Alert 2020-2442) Legislation — Oct 16: What to expect in Washington (October 16) (Tax Alert 2020-2488) — Oct 13: Read the latest on tax policy and the US elections (Tax Alert 2020-2454) — Oct 09: New US DHS H-1B strengthening and DOL wage rules discussed (Tax Alert 2020-2446) States — Oct 15: Statement by government official suggests that proposed foreign tax credit regulations would not affect the credit claimed by US related parties for the excise tax paid to Puerto Rico under Act 154 (Tax Alert 2020-2482) — Oct 15: September 2020 jobless rate continues decline; more states take federal loans to fund UI benefit claims (Tax Alert 2020-2475) — Oct 13: Alabama adopts new policy requiring annual renewal of most tax registrations beginning November 1, 2020 (Tax Alert 2020-2466) — Oct 13: Social Security wage base to increase in 2021 (Tax Alert 2020-2465) — Oct 13: California law expands COVID-19 supplemental paid sick leave to all employers through end of 2020; several California cities and counties have also enacted similar ordinances (Tax Alert 2020-2461) ————————————————————————— State and Local Tax Weekly — Ohio Supreme Court ruling provides first judicial guidance on Commercial Activity Tax sourcing rule for gross receipts not otherwise sitused. In Defender Security Co. v. McClain, the Ohio Supreme Court (Court) ruled that a company's receipts from the sale of customer contracts to another business are properly sitused to the out-of-state physical locations where the business purchaser received the benefit of the purchased contracts. In so finding, the Court reversed the denial of the company's refund claim for Commercial Activity Tax (CAT) by the Ohio Department of Taxation (OH DoT). The Court remanded the case back to the OH DoT to issue the refunds. — New California law allows certain nonresident aliens to elect to file group returns instead of individual returns. On Sept. 18, 2020, Governor Gavin Newsom signed into law AB 2660 (2020 Cal. Stats., ch. 102) (AB 2660), allowing nonresident aliens who are not eligible for, or have not been issued, a Social Security number (SSN) or an Individual Taxpayer Identification Number (ITIN) to elect to file a group return instead of an individual return for taxable income received for services that take place in California. As a result, the nonresident alien can make the election without having to provide an SSN or ITIN. — Income/Franchise, Sales & Use, Business Incentives, Property Tax, Controversy, Payroll & Employment Tax, Miscellaneous Tax, Global Trade, Upcoming Webcasts ————————————————————————— Final Regulations
Revenue Procedures
Notices
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. | |||||||||||||||||||
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