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11 June 2023

U.S. International Tax This Week for June 9

Ernst & Young's U.S. International Tax This Week newsletter for the week ending June 9 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

Republican House Ways and Means Committee members are expected to soon release proposals that would address certain TCJA tax provisions (among others), with a committee markup of the bill possibly the week of 12 June. According to press reports, the measures reportedly will include restoring R&D expensing in place of the Section 174 R&D five-year amortization requirement, the prior-law calculation for the Section 163(j) interest deduction limitation, and the bonus depreciation phasedown.

Treasury and the IRS on 7 June released Notice 2023-42, providing penalty relief for corporations that did not pay estimated tax in regard to the new 15% corporate alternative minimum tax (CAMT) enacted by the Inflation Reduction Act. According to an IRS press release, the government has taken into consideration the "challenges" in determining CAMT liability as well as whether or not an applicable corporation is subject to the CAMT.

The IRS is planning to issue additional guidance in regard to US inbound and outbound intellectual property (IP) transfers that will address issues that were not covered in recent proposed regulations. Treasury and the IRS issued proposed regulations on 2 May, that would apply new rules to "repatriations" of IP subject to Section 367(d). In certain circumstances, the proposed regulations would permit the annual inclusions that Section 367(d) and its regulations require, to cease. An IRS official this week was quoted as saying there will be "subsequent packages" or rules, one or more of which will relate to Section 367(d). The official did not offer a timeline.

President Biden has nominated Marjorie Rollinson to be the next IRS Chief Counsel, one of only two IRS positions requiring Senate confirmation. Rollinson spent most of her career at EY, retiring as EY Deputy Director of National Tax, and has held several senior positions at the IRS including Associate Chief Counsel (International).

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Upcoming Webcasts

How to understand the new class of tax authority governance programs in Americas and EMEIA (June 14)
During this EY Webcast for Americas and EMEIA audiences, EY professionals will describe the rapidly growing focus of business and tax authorities on tax governance.

Tax in a time of transition: Legislative, economic, regulatory and IRS developments (June 16)
Please join us for a fast-paced overview of recent tax and economic developments designed to help you stay on top of changes in today’s shifting economic, legislative and regulatory environment. In this regularly occurring EY Webcast series, panelists will provide updates on: (i) the US economy and tax policy; (ii) what’s happening at the IRS; and (iii) breaking developments.

Finance and treasury: How to navigate the changing global tax landscape (June 28)
During this EY Webcast, Ernst & Young professionals will discuss key tax trends and topics that will affect global finance and treasury activities.

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Recent Tax Alerts

United States

Africa

Asia

Canada & Latin America

Europe

Middle East

Oceania

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2023-24Internal Revenue Bulletin of June 12, 2023

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Additional Resources

EY’s Tax News Update, 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:

— EY’s Tax and Law Guides. Tax and Law Guides | EY - Global 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: 2023-1032

 

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.

 

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