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July 28, 2023
2023-1323

U.S. Tax This Week for July 28

Ernst & Young's U.S. Tax This Week newsletter for the week ending July 28 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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Top of the Week

OECD releases public Consultation Document on Pillar One Amount B on baseline distribution

Among the series of technical documents released by the Organisation for Economic Co-operation and Development (OECD) on 17 July 2023 focusing on the ongoing OECD/G20 project on addressing the tax challenges of the digitalization of the economy (the BEPS 2.0 project) is a public Consultation Document on Amount B of Pillar One. Amount B provides for fixed returns for in-scope in-country baseline marketing and distribution activities. EY Tax Alert 2023-1316 has details.

OECD/G20 Inclusive Framework releases document on Pillar Two GloBE Information Return

Among the series of documents that the Organisation for Economic Co-operation and Development (OECD) released on 17 July focusing on elements of the OECD/G20 project addressing the tax challenges of the digitalization of the economy (the BEPS 2.0 project) is a document on the GloBE Information Return (GIR). This document, which has been approved by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), contains an overview of the GIR and how it is intended to operate, the template for the GIR itself, and explanatory guidance on the GIR. EY Tax Alert 2023-1294 has details.

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EY Guides, Surveys, and Reports

Global Immigration Trends and Highlights | April - June 2023
This publication provides a snapshot of corporate immigration developments worldwide. It is designed to support conversations regarding policies that have been proposed or implemented in key jurisdictions in the Americas, Asia-Pacific and EMEIA (Europe, Middle East, India, Africa) regions.

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Upcoming Webcasts

Tax in a time of transition: Legislative, economic, regulatory and IRS developments (August 18)
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.

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Recent Tax Alerts

Courts

— Jul 26: Third Circuit reverses Tax Court, holds deadline for redetermination petition is not jurisdictional and is subject to equitable tolling (Tax Alert 2023-1303)

Internal Revenue Service

— Jul 21: Tax M&A Update for June 2023 (Tax Alert 2023-1289)

International

— Jul 27: UK publishes requirements for Transfer Pricing records (Tax Alert 2023-1321)

— Jul 27: G20 Finance Ministers welcome progress made on BEPS 2.0 project (Tax Alert 2023-1318)

— Jul 26: OECD releases public Consultation Document on Pillar One Amount B on baseline distribution (Tax Alert 2023-1316)

— Jul 26: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations (Tax Alert 2023-1315)

— Jul 26: Pacific Alliance Double Taxation Convention on pensions funds will apply beginning 1 January 2024 (Tax Alert 2023-1313)

— Jul 26: Costa Rica Tax Authority intends to scrutinize taxpayers claiming loss or zero profit on FY22 Corporate Income Tax returns (Tax Alert 2023-1312)

— Jul 26: Argentina applies tax on purchases of foreign currency in new transactions, provides preferential foreign-exchange rate to certain exported goods (Tax Alert 2023-1309)

— Jul 26: East African Community implements tariff changes for the Financial Year 2023/24 (Tax Alert 2023-1308)

— Jul 26: Philippines launches online platform for several immigration applications (Tax Alert 2023-1307)

— Jul 25: OECD/G20 Inclusive Framework releases Subject to Tax Rule model treaty provision and commentary (Tax Alert 2023-1302)

— Jul 25: German Ministry of Finance proposes interest-rate limitation rule (Tax Alert 2023-1301)

— Jul 25: China Mainland resumes visa-free travel for nationals of Brunei and Singapore (Tax Alert 2023-1300)

— Jul 25: Finnish Consulate in Saint Petersburg to close by 1 October 2023 (Tax Alert 2023-1299)

— Jul 24: Canada's new mandatory disclosure rules now in effect (Tax Alert 2023-1298)

— Jul 24: OECD/G20 Inclusive Framework releases document on Pillar Two GloBE Information Return (Tax Alert 2023-1294)

— Jul 21: OECD/G20 Inclusive Framework releases additional Administrative Guidance on Pillar Two GloBE Rules: Detailed review (Tax Alert 2023-1292)

— Jul 21: Egypt introduces amendments to the Income Tax Law (Tax Alert 2023-1290)

— Jul 21: European Commission releases new rules as part of Circular Economy Action Plan: textiles and batteries waste (Tax Alert 2023-1287)

Legislation

— Jul 26: What to expect in Washington (July 26) (Tax Alert 2023-1306)

States

— Jul 27: Maine law establishes a state paid family and medical leave program with contributions starting in 2025 (Tax Alert 2023-1317)

— Jul 26: Missouri Supreme Court declines to hear case on whether class action suit may be brought by St. Louis teleworkers owed earnings tax refunds (Tax Alert 2023-1314)

— Jul 21: New Jersey implements "convenience of the employer rule" for certain nonresident employees, provides tax incentives to certain taxpayers and businesses (Tax Alert 2023-1291)

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Recent Newsletters

State and Local Tax Weekly
   Highlights of this edition include:

— New Jersey Governor signs bill overhauling Corporation Business Tax. On July 3, 2023, New Jersey Governor Phil Murphy signed into law SB 3737 / AB 5323 (the Legislation), which significantly overhauls key aspects of the Corporation Business Tax Act (the CBT Act).

— Income/Franchise, Sales & Use, Business Incentives, Property Tax, Controversy, Payroll & Employment Tax, Miscellaneous Tax, Global Trade, Value Added Tax

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IRS Weekly Wrap-Up

Final Regulations

 TD 9978Recapture of Certain Excess Employment Tax Credits Under COVID-19 Legislation

Revenue Procedures

 2023-26Rulings and determination letters

Notices

 2023-53Update for weighted average interest rates, yield curves, and segment rates
 2023-54Transition relief and guidance relating to certain required minimum distributions
 2023-55Temporary relief under Sections 901 and 903 of the internal revenue code

Internal Revenue Bulletin

 2023-31Internal Revenue Bulletin of July 31, 2023

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.

 

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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