August 16, 2024 Report on recent US international tax developments - 16 August 2024 Tax and other economic policy issues are a significant focus in the US presidential race with the pending fiscal cliff of Tax Cuts and Jobs Act provisions expiring at the end of 2025. In earlier remarks, former President Trump said, "We will pass massive tax cuts for workers and that includes no tax on tips." He also expressed concern about the expansion of the IRS workforce following enactment of the Inflation Reduction Act. On the Democrat side, there is expected to be general continuity with Biden Administration policy positions now that Vice President Harris is the presumptive nominee, though there were some differences between President Biden's and Harris's positions on tax and other issues when they were candidates for the 2020 election. The Vice President will offer more details on her economic and tax agenda later today (16 August) in a policy speech. A press release today provides some insights into her proposed agenda for her first 100 days in office, if elected, particularly with regard to families and housing. According to the release, Vice President Harris is proposing (1) adding a first-ever tax incentive for building starter homes, (2) expanding the Child Tax Credit, and (3) lowering the cost of prescription drugs and groceries, among other proposals. The IRS on 9 August released an early draft version of 2025 Form 1099-DA, Digital Asset Proceeds from Broker Transactions, along with instructions for recipients of the form. Draft instructions for filers will be posted soon. The form is meant for brokers to report digital asset sales and exchange transactions — including for cryptocurrency — that take place beginning in 2025. The forms will be sent separately to the taxpayers and the IRS in 2026. According to the IRS, the draft form reflects the final regulations for custodial broker reporting released in June 2024 as well as transitional relief provided in Notice 2024-56, Notice 2024-57 and Revenue Procedure 2024-28. The IRS, on 15 August, announced that it is expanding the Compliance Assurance Process (CAP) program to include privately held corporations, including companies that are foreign-owned. The 2025 CAP application period will extend from 4 September through 31 October 2024. CAP previously was only available to publicly held corporations. See the IRS's Highlights and updates for the CAP 2025 application period for more details. CAP is a cooperative pre-filing program available to certain large taxpayers that is intended to allow the IRS and taxpayers reach agreement on the treatment of various tax issues before a return is filed. CAP began as a pilot program in 2005 and became permanent in 2011. Publicly traded corporations could apply to the program beginning in the 2020 CAP year. The Organisation for Economic Co-operation and Development (OECD) on 12 August published a report titled, Determining the Price of Minerals: A transfer pricing framework for lithium. The report applies the OECD/Intergovernmental Forum mineral pricing framework to "identify the primary economic factors that influence the price of lithium in applying the Comparable Uncontrolled Price method."
| ||||
|
