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August 20, 2023

U.S. International Tax This Week for August 18

Ernst & Young's U.S. International Tax This Week newsletter for the week ending August 18 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.


The IRS recently announced that taxpayers that are not under examination will now have a better option to electronically request relief for certain late-filed international documents and forms. The new option, part of the IRS’s paperless processing initiative, will allow for eFax filings and will apply to Relief for Gain Recognition Agreements, Late Filing Relief for Dual Consolidated Losses, and Relief for Partnership Gain Deferral Contributions.

A Treasury Financial Crimes Enforcement Network (FinCEN) rule that would extend the beneficial ownership information reporting deadline for reporting companies created or registered in 2024 is closer to release. The proposed rule that would extend the deadline was sent on to the OMB’s Office of Information and Regulatory Affairs (OIRA) for review on 14 August, according to the OIRA website. Details of the extended deadline are not yet available. According to the summary of the disclosure rules released in 2022, reporting of certain information about beneficial ownership is intended to help prevent and combat certain activity such as money laundering and tax fraud. The final rule on beneficial ownership information reporting requirements is available here.

The OECD Director of the Centre for Tax Policy and Administration said this week that certain open issues related to Amount A in Pillar One (new nexus/taxing right) in the upcoming Multilateral Convention (MLC) are expected to be resolved by early fall. Manal Corwin said during a public podcast that, “there are a small number of discrete technical points that involve a few jurisdictions, and when those are resolved, that will put us in a position to then finalize the text of the MLC.”

Upcoming Webcasts

Tax and Finance Operate: Now. Next. Beyond. (August 23)
During this EY webcast, EY Global Compliance and Reporting practitioners will explore the current tax and finance operations landscape and share insights and results from the recently released EY survey. They will be joined by senior tax executives from Mondelez International, Inc. and UPS, who will share how their companies successfully revolutionized their tax and finance function and established a new tax operating model. They’ll also share practical approaches for industry professionals navigating global tax and finance operations.

BorderCrossings ... With EY transfer pricing and tax professionals (August 31)
During this EY webcast, Ernst & Young professionals examine the difficulties in applying transfer pricing rules to attribute profits to permanent establishments considering both US and international tax treaties. Under US tax treaties, Article 7 governs profit attribution to permanent establishments and references the arm’s-length principle under Article 9. In response to a lack of clear and consistent interpretation of profit attribution under international tax treaties, the Organisation for Economic Co-operation and Development (OECD) developed the Authorized OECD Approach (AOA).

International tax talk quarterly series with the EY Global Tax Desk Network (September 12)
Recent proposed tax changes across the globe may have significant implications for companies in the next quarter and beyond. Some of these changes are complex, so it is important that businesses understand them and try to prepare now – particularly for those that take effect in 2024. Please join our EY webcast for insights on recent developments in Australia, Brazil, Hong Kong, Mexico, Switzerland, and the United States and an analysis of how they might affect your businesses.

EY Guides and Publications

EY publication highlights 2023 Q2 tax policy developments across the Americas
The second quarter of 2023 ushered in several significant tax policy developments across the Americas from April through June 2023. Highlights discussed include (i) agreement to form a Regional Tax Cooperation Platform for the LATAM Region; (ii) OECD releases 2023 report on tax transparency in Latin America; (iii) Brazil transfer pricing law enforceable beginning 1 January 2024;  and (iv) US Senate approval of US - Chile tax treaty brings treaty closer to entering into force.

Recent Tax Alerts


— Aug 15: Kenya Revenue Authority notice clarifies allowances subject to Affordable Housing Levy, 2023 (Tax Alert 2023-1407)

— Aug 15: Egypt introduces further tax incentives to stimulate foreign direct investments (Tax Alert 2023-1404)


— Aug 17: Japan's visa exemption for Brazilian business visitors to go into effect on 30 September 2023 (Tax Alert 2023-1414)

— Aug 11: Hong Kong-Mauritius Double Taxation Avoidance Agreement enters into force in Mauritius from 23 June 2023 (Tax Alert 2023-1391)

Canada & Latin America

— Aug 18: Canada releases further revisions to EIFEL proposals (Tax Alert 2023-1421)

— Aug 17: Brazil's visa exemption for Japanese business visitors to go into effect on 30 September 2023 (Tax Alert 2023-1413)

— Aug 17: Bermuda's consideration of adopting a corporate income tax has significant implications for insurance industry (Tax Alert 2023-1412)

— Aug 16: Brazil's Complimentary Law number 199 simplifies tax obligations (Tax Alert 2023-1410)

— Aug 11: Canada's new Recognized Employer Pilot (REP) Program under Temporary Foreign Worker (TFW) Program discussed (Tax Alert 2023-1395)


— Aug 18: European Commission adopts final Implementing Regulation for transitional phase of CBAM (Tax Alert 2023-1422)

— Aug 15: Polish Government seeks annulment of CBAM regulation in European Court of Justice (Tax Alert 2023-1405)

— Aug 11: Luxembourg publishes draft legislation on implementation of the EU Minimum Tax Directive (Tax Alert 2023-1396)


— Aug 15: New Zealand's Inland Revenue Department announces 2022 tax governance work results, further program expansion (Tax Alert 2023-1403)

IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2023-34Internal Revenue Bulletin of August 21, 2023

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.