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September 24, 2023
2023-1583

U.S. International Tax This Week for September 22

Ernst & Young's U.S. International Tax This Week newsletter for the week ending September 22 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

Budget negotiations are continuing as House Republicans look for agreement on a continuing resolution (CR) to fund the federal government past the 30 September deadline that can garner enough votes to pass the chamber. Assuming passage of a CR in the House, the bill would still require Senate approval and the President's signature to avoid a government shutdown.

The tax press reported this week that House Republican tax lawmakers want countries to delay their implementation of BEPS Pillar Two, while also urging nations to adopt rules similar to the US Global Intangible Low-taxed income (GILTI) regime. According to the report, the focus has moved from the OECD to getting countries on board to adopt something akin to GILTI.

A House Ways and Means Committee delegation recently traveled to Europe to explain to OECD and European officials Congress's concerns regarding the BEPS 2.0 project. Among other things, Ways and Means Chairman Jason Smith (R-MO) delivered the message that the US already has a global minimum tax in the GILTI regime and does "not object to others implementing their own GILTI-type taxes." The Chairman also reportedly warned that the US "will not suddenly repeal our proven system in favor of an untested regime with substantial complexity and uncertainty." In the Senate, the Finance Committee announced a hearing for 28 September to consider nominations, including that of Marjorie Rollinson to be the next IRS Chief Counsel. 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

BorderCrossings with EY transfer pricing and tax professionals ... OECD BEPS 2.0 transfer pricing update (September 28)
During this EY Webcast, Ernst & Young professionals will provide a transfer pricing update on the Base Erosion and Profit Shifting (BEPS) 2.0 initiative of the Organisation for Economic Co-operation and Development (OECD), with particular emphasis on Pillar One and the country-by-country (CbC) report safe harbor that is part of Pillar Two.

Refocusing on the global trade functional organization ... A global trade perspective (October 5)
Global trade professionals have navigated higher customs duty costs, increased complexity from the ever-changing regulatory environment, and a need for increased operational efficiencies to help reduce supply chain delays. During this EY Webcast, Ernst & Young professionals will share the benchmarking results of peer global trade professionals on how they are organizing their global trade functions to be more efficient, reduce customs duty costs and effectively manage risks, also taking into consideration technology advancements.

Spotlight on BEPS 2.0: developments and practical implications for US MNEs (October 11)
Global minimum tax rules are set to take effect as soon as 2024, and many multinational entities (MNEs) still have a lot to do to prepare. To help with these efforts, EY is launching a one-hour webcast series focused on steps MNEs can take to prepare for, and comply with, these new rules. During this EY Webcast, Ernst & Young Pillar Two subject-matter professionals for an action-oriented panel discussion, moderated by EY’s Jose Murillo, National Tax Department Leader and former US Department of the Treasury Deputy Assistant Secretary (International Tax Affairs).

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Recent Tax Alerts

United States

— Sep 15: USCIS issues policy guidance to clarify eligibility for Extraordinary Ability and Outstanding Professor/Researcher immigrant visa classifications (Tax Alert 2023-1542)

Asia

— Sep 19: Hong Kong and Bangladesh sign comprehensive double taxation arrangement (Tax Alert 2023-1557)

— Sep 19: Indonesia introduces new Golden Visa route (Tax Alert 2023-1555)

— Sep 15: Taiwan announces foreign institutional investors may use Taiwan-listed stocks as collateral for offshore investment activities (Tax Alert 2023-1538)

Canada & Latin America

— Sep 21: Canada | Distributed investment plans required to request certain investor information by 15 October 2023 (Tax Alert 2023-1579)

— Sep 20: Costa Rican President partially vetoes law aimed at making reforms to achieve exclusion from EU list of non-cooperative jurisdictions in tax matters (Tax Alert 2023-1571)

— Sep 20: Argentine Government proposes to evaluate a 15% corporate minimum tax (Tax Alert 2023-1564)

— Sep 19: Mexico eliminates COVID-19-related relaxation of immigration deadlines for residence permit holders (Tax Alert 2023-1562)

— Sep 18: Uruguay extends VAT rate-reduction period for tourism sector (Tax Alert 2023-1553)

— Sep 18: Brazil to begin issuing new visa and residence permits for nationals of Community of Portuguese Language Countries (Tax Alert 2023-1550)

Europe

— Sep 20: Luxembourg legislation modernizes subscription tax regime (Tax Alert 2023-1565)

— Sep 19: Netherlands budget proposals: Key legislative developments for 2024 and 2025, including Pillar Two minimum tax (Tax Alert 2023-1563)

— Sep 19: Luxembourg implements new immigration regulations for employers, third-country nationals and dependents (Tax Alert 2023-1554)

— Sep 18: UK's new visa application fees to go into effect on 4 October 2023 (Tax Alert 2023-1549)

— Sep 18: Bulgaria planning to introduce SAF-T, affecting most businesses (Tax Alert 2023-1548)

— Sep 15: Irish Government publishes roadmap for introducing dividend participation exemption to Ireland's corporation tax system (Tax Alert 2023-1543)

— Sep 15: European Commission proposes BEFIT and Transfer Pricing Directives (Tax Alert 2023-1537)

Middle East

— Sep 21: Qatar mandates health insurance policy for multi-entry work visa holders (Tax Alert 2023-1574)

— Sep 19: Saudi Arabia approves amendments to Income Tax Bylaws and Zakat Regulations (Tax Alert 2023-1556)

— Sep 15: Turkiye's Constitutional Court annuls rule that allows blocking access to digital services upon default on Digital Services Tax liability (Tax Alert 2023-1536)

Multinational

— Sep 20: The Latest on BEPS and Beyond | September 2023 (Tax Alert 2023-1566)

— Sep 19: Global Tax Policy and Controversy Watch | September 2023 edition (Tax Alert 2023-1560)

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2023-37Internal Revenue Bulletin of September 11, 2023
 2023-38Internal Revenue Bulletin of September 18, 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.

 

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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