June 26, 2022
U.S. Tax This Week for June 24
Ernst & Young's U.S. Tax This Week newsletter for the week ending June 24 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.
Top of the Week
IRS TE/GE division changes procedures for responding to numerous simultaneous referrals regarding the same exempt organization/employee plan
In a new memorandum (TEGE-04-0622-0028) (Memo), the IRS Tax Exempt/Government Entities (TE/GE) Director of Compliance Planning and Classification has announced a change to procedures for sending certain acknowledgement letters to individuals who submit referrals for examination to the IRS regarding an exempt organization, employee plan or government entity when TE/GE receives more than 10 referrals for the same organization in a short period. EY Tax Alert 2022-0966 has details.
UK delays implementation of OECD Pillar Two to accounting periods beginning on or after 31 December 2023
On 14 June 2022, along with other respondents to the United Kingdom's (UK) consultation on the implementation of the Organisation for Economic Co-operation and Development (OECD) Pillar Two, EY received a letter from the UK Financial Secretary to the Treasury (FST) providing an update on the work to implement the OECD Pillar Two rules in the UK and what to expect in the coming months. EY Tax Alert 2022-0954 has details.
EY Guides and Publications
QUEST Economic Update highlights key US and global economic trends - June 21, 2022
EY's Quantitative Economics and Statistics (QUEST) group has developed the attached publication summarizing the latest key economic and employment trends in a short, easy-to-read format. Developments such as growth trends in US gross domestic product (GDP), US employment and Federal Reserve activity are highlighted, as are economic trends outside the United States that may affect US businesses.
Competent Authority procedures in cross-border controversy for new entrants (June 28)
During this EY Webcast, Ernst & Young professionals will discuss trends and developments in Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in jurisdictions that are new entrants or have new developments.
Competent Authority procedures in cross-border controversy at hub jurisdictions (June 30)
During this EY Webcast, Ernst & Young professionals will discuss trends and developments in Advance Pricing Agreements (APAs) and Mutual Agreement Procedure (MAP) in hub jurisdictions for centralized business operating models.
BorderCrossings (June 30)
During this EY Webcast, Ernst & Young professionals will discuss the current scope and framework of the Pillar One and Pillar Two proposals, the impact on multinationals, a US legislative update on related matters, and next steps.
Tax in the time of COVID-19: Update on legislative, economic, regulatory and IRS developments (July 1)
During this EY Webcast, Ernst & Young professionals will discuss how businesses can navigate the tax policy environment and continue to effectively operate their tax function in this time of crisis and change. Panelists will provide updates on: (i) the US economy and tax policy; (ii) breaking developments; and (iii) what’s happening at the IRS.
Taxing crypto and other digital assets: Using practical scenarios to explore key tax concepts for individuals and businesses (July 21)
During this EY Webcast, Ernst & Young professionals will discuss recent digital assets' tax trends and the outlook for changes relevant to individuals and financial services companies.
Recent Tax Alerts
— Jun 23: Accountable care organization petitions Tax Court to challenge IRS denial of 501(c)(4) status (Tax Alert 2022-0975)
— Jun 22: US Supreme Court grants cert to hear FBAR penalty application case (Tax Alert 2022-0969)
Internal Revenue Service
— Jun 09: Two new reports analyze 2019 community benefits of tax-exempt hospitals, federal revenue forgone due to tax exemption (Tax Alert 2022-0900)
— Jun 23: Tanzania’s Parliament passes Finance Bill 2022 (Tax Alert 2022-0972)
— Jun 21: Supreme Court of Canada closes another door on equitable relief (Tax Alert 2022-0968)
— Jun 21: Saudi Arabia relaunches tax amnesty initiative (Tax Alert 2022-0963)
— Jun 20: Luxembourg and the United Kingdom sign new double tax treaty (Tax Alert 2022-0960)
— Jun 20: US Customs and Border Protection releases operational guidance related to Uyghur Forced Labor Prevention Act implementation (Tax Alert 2022-0958)
— Jun 20: EU Finance Ministers are unable to adopt Pillar Two Directive as Hungary changes position (Tax Alert 2022-0957)
— Jun 20: German Ministry of Finance issues report on extraterritorial taxation of intellectual property to German Parliament (Tax Alert 2022-0956)
— Jun 20: Türkiye's Country-by-Country Reporting Notification deadline is 30 June 2022 (Tax Alert 2022-0955)
— Jun 23: Senate Finance approves retirement bill (Tax Alert 2022-0974)
— Jun 22: What to expect in Washington (June 22) (Tax Alert 2022-0970)
— Jun 20: Senate Finance outlines retirement bill (Tax Alert 2022-0961)
— Jun 17: House Committee on Energy and Commerce hearing on protecting America's consumers: Bipartisan legislation to strengthen data privacy and security (Tax Alert 2022-0943)
— Jun 17: Senate HELP Committee advances user fee agreements and three public health bills to full Senate (Tax Alert 2022-0942)
— Jun 21: Ohio enacts elective pass-through entity tax (Tax Alert 2022-0967)
— Jun 20: Iowa enacts additional tax legislation changing bank franchise tax rate and sales and use tax (Tax Alert 2022-0964)
— Jun 17: Potential repeal of Puerto Rico's 4% excise tax on foreign corporations is on the horizon (Tax Alert 2022-0951)
— Jun 20: Delaware enacts law to implement a paid family and medical leave insurance program with contributions starting in 2025 (Tax Alert 2022-0950)
— Jun 17: New Jersey Division of Taxation offers new transfer pricing initiative that runs through March 2, 2023 (Tax Alert 2022-0947)
State and Local Tax Weekly
Highlights of this edition include:
— New Jersey publishes proposed combined reporting regulations for public comment On May 16, 2022, the New Jersey Division of Taxation (NJ DOT) published proposed combined reporting regulations (the "Proposed Regulations") in the New Jersey Register. Interested parties may submit comments until July 15, 2022.
— Income/Franchise, Sales & Use, Business Incentives, Property Tax, Controversy, Payroll & Employment Tax, Miscellaneous Tax, Unclaimed Property, Value Added Tax, Unclaimed Property
IRS Weekly Wrap-Up
| ||2022-28||IRS Will Not Rule on Whether Transactions Result in Employer Reversions|
| ||2022-29||Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates|
Internal Revenue Bulletin
| ||2022-26||Internal Revenue Bulletin of June 27, 2022|
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.