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October 1, 2023

U.S. International Tax This Week for September 29

Ernst & Young's U.S. International Tax This Week newsletter for the week ending September 29 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.


Congress is continuing to take steps to pass a continuing resolution (CR) to extend government funding past the 30 September midnight deadline, but some members believe a shutdown of some sort seems inevitable. The potential for an agreement may come down to border security, which House Speaker Kevin McCarthy (R-CA) continues to press as an issue of wide support, and which is the subject of a bipartisan amendment under development in the Senate.

Marjorie Rollinson, President Biden's pick to become IRS Chief Counsel and Treasury Assistant General Counsel, testified at her Senate Finance Committee confirmation hearing on 28 September. 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).

International tax was one area of focus for committee Republicans during the confirmation hearing. Ranking Member Mike Crapo (R-ID) said the Administration "invited foreign governments to pursue new discriminatory taxes against our companies in the form of the Undertaxed Profits Rule (UTPR), a surtax which also likely violates our existing bilateral tax treaties." According to Senator Crapo, a collateral consequence was that "Treasury must now exhaust precious resources issuing regulations to attempt to mitigate the double taxation it created by unilaterally committing to a global tax deal that undermines U.S. interests."

The timing for further action on the Rollinson nomination is not clear at this time.

A group of bipartisan members of the House Ways and Means Committee on 19 September sent a letter to Treasury Secretary Janet Yellen and US Trade Representative Katherine Tai expressing their disapproval of Canada's decision to move forward with plans to introduce a 3% Digital Services Tax (DST). The proposed Canadian DST would be effective 1 January 2024 and apply retroactively to 1 January 2022. The Committee members warned that the United States "would examine all options, including under our trade agreements and domestic statutes," if Canada introduces the DST.

Upcoming Webcasts

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. This EY Webcast, 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. Join 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).

How to energize a workforce in the great rebalance (October 17)
During this EY Webcast, Ernst & Young professionals will explore the EY 2023 Work Reimagined Survey with insights from 17,050 employees and 1,575 employers in 22 countries, revealing the contours of new workforce realities.

How transferable tax credits are changing the tax landscape (October 17)
The Inflation Reduction Act (IRA) introduced federal transferable tax credits. During this EY Webcast, Ernst & Young professionals will cover many FAQs, including which tax credits are transferable, an update on the contents of the recently released proposed regulations and how the transfer process works.

Business impacts of sustainability and ESG tax policies (October 18)
During this first in a quarterly series of EY Webcasts, Ernst & Young professionals will be discussing the role of tax in sustainability and how it can impact businesses’ ESG strategy and operations. Topics will include: (i) the impact of sustainability on business and tax operations; (ii) the sustainability tax landscape; and (iii) the legislative and tax policy emphasis on climate change.

EY Tax.Tech™ Ecosystem series: Finance and Tax convergence - the next transformation frontier (October 19)
In this dynamic, complex, and competitive landscape, Finance and Tax alignment is critical and can unlock data to help identify synergies and establish viable and enduring business value. During this EY Webcast, we will explore how Thomson Reuters tax and accounting clients have adopted a transformation mindset through better aligning with the finance agenda, integrating into an enterprise resource planning (ERP) strategy, and helping their people, processes and technology improve their tax function and better utilize their ONESOURCE suite of products.

Tax in a time of transition: legislative, economic, regulatory and IRS developments (October 20)
During this EY Webcast, panelists will provide updates on: (i) the US economy and tax policy; (ii) what’s happening at the IRS; and (iii) breaking developments.

Recent Tax Alerts

United States

— Sep 25: United States government set to suffer lapse in funding to begin fiscal year 2024 (Tax Alert 2023-1597)

— Sep 22: US IRS rules converting disregarded entity to domestic corporation does not modify debt (Tax Alert 2023-1590)


— Sep 22: Kenya eliminates visa requirement for nationals of the Democratic Republic of the Congo (Tax Alert 2023-1587)


— Sep 28: Vietnam implements new employer obligations and changes to work permit requirements (Tax Alert 2023-1614)

— Sep 27: Georgia implements new requirements for employers that hire foreign nationals (Tax Alert 2023-1606)

— Sep 25: India suspends issuance of visas to Canadian nationals (Tax Alert 2023-1598)

Canada & Latin America

— Sep 27: Canada introduces legislation on enhanced GST rental rebate for new rental units (Tax Alert 2023-1611)

— Sep 27: Egyptian embassy in Ottawa announces new visa requirement for Canadian nationals effective 1 October 2023 (Tax Alert 2023-1607)

— Sep 22: Panama implements stricter entry requirements for certain foreign nationals, including business travelers (Tax Alert 2023-1589)


— Sep 28: Italy's new Enabling Law for Tax Reform foreshadows positive changes to cooperative compliance program (Tax Alert 2023-1616)

— Sep 27: European Commission proposes Head Office Tax System Directive for SMEs (Tax Alert 2023-1609)

— Sep 26: Germany approves new citizenship regulations (Tax Alert 2023-1601)

— Sep 26: European Commission proposes extending the Temporary Protection Directive until 3 March 2025 (Tax Alert 2023-1600)

— Sep 22: Sweden's new salary requirement expected to go into effect on 1 November 2023 (Tax Alert 2023-1588)

Middle East

— Sep 28: Saudi Arabia releases new draft Zakat Bylaws for public consultation (Tax Alert 2023-1615)

— Sep 25: Turkiye amends accounting standards to align with BEPS 2.0 Pillar Two legislation (Tax Alert 2023-1596)

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.