Federal Tax | State & Local Tax | International Tax Human Capital & Workforce, Individual and Indirect Tax This year in review lists all EY Tax Alerts concerning significant U.S. international tax developments, as well as key OECD BEPS developments, during 2024. |
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Key U.S. international tax developments, 2024 |
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01.17.2025 | Treasury finalizes regulations on review of federal tax controversies by IRS Appeals office (2025-0269) |
01.10.2025 | Abbott petitions Tax Court to redetermine deficiencies for 2020 (2025-0195) |
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12.19.2024 | IRS official confirms that IRS can apply economic substance doctrine to transfer pricing cases (2024-2345) |
12.19.2024 | US Court of Federal Claims again holds that US citizen may offset net investment income tax with treaty-based credit under US - Canada income tax treaty (2024-2350) |
12.19.2024 | US taxpayers may elect OECD's simplified and streamlined approach to intercompany transactions beginning in 2025 (2024-2351) |
12.13.2024 | United States | Final and proposed regulations on qualified business units retain foreign exchange exposure pool method under Section 987, with simplifying elections (2024-2298) |
12.06.2024 | Long-awaited US proposed regulations address certain PTEP complexities (2024-2229) |
12.05.2024 | US | FinCEN continues to extend certain signature authority reporting (FBAR, Form 114) (2024-2218) |
12.02.2024 | FIRST IMPRESSIONS | US Treasury and IRS propose long-awaited regulations on previously taxed earnings and profits of foreign corporations (2024-9006) |
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11.25.2024 | OECD's 2023 mutual agreement procedure statistics show continued strength in the US program (2024-2149) |
11.11.2024 | IRS representative indicates that corporations failing to respond to transfer pricing compliance letters have been referred for examination (2024-2067) |
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10.25.2024 | Abbott files petition with Tax Court regarding deficiency determinations for 2017 and 2018 (2024-1960) |
10.14.2024 | United States | Final IRC Section 367(d) regulations open door to intangible property repatriation for US multinationals (2024-1885) |
10.08.2024 | IRS revenue ruling states that the European Energy Exchange is a "qualified board or exchange" under IRC Section 1256(g)(7)(C) (2024-1844) |
10.04.2024 | San Francisco voters to decide on changes to the City's business taxes (2024-1825) |
10.02.2024 | IRS revenue ruling states that Bourse de Montréal (MX) is a "qualified board or exchange" within the meaning of IRC Section 1256(g)(7)(C) (2024-1800) |
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09.30.2024 | US IRS representatives say IRS will evaluate transfer pricing documentation and method when deciding on penalties (2024-1791) |
09.25.2024 | Irish Tax Appeal Commission rules on treatment of stock-based compensation in services cost base transfer pricing dispute (2024-1765) |
09.17.2024 | Sixth Circuit grants stay on enforcing IRS summons requesting foreign employee performance evaluations in transfer pricing audit (2024-1711) |
09.13.2024 | US IRS issues penalty relief for failure to pay remaining estimated CAMT installments for 2024 (2024-1688) |
09.10.2024 | US Tax Court allows a domestic corporation to claim IRC Section 245A DRD for IRC Section 78 dividend on IRC Section 965 inclusion from fiscal-year CFCs but reduces FTC claim (2024-1662) |
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08.23.2024 | US IRS issues new proposed regulations that limit or modify taxpayers' ability to make or revoke certain foreign currency elections (2024-1600) |
08.11.2024 | United States | US Treasury provides guidance on the interaction of DCLs with Pillar Two taxes and introduces new "disregarded payment losses" rules (2024-1529) |
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07.30.2024 | US Court of Appeals holds that a nonresident's gain from the sale of its US partnership interest attributable to inventory is not US-source income, reversing an earlier Tax Court decision (2024-1462) |
07.23.2024 | US Supreme Court overrules Chevron deference to agency regulations (2024-1432) |
07.19.2024 | Final IRC Section 367(b) regulations address certain cross-border triangular reorganizations and inbound nonrecognition transactions (2024-1416) |
07.18.2024 | IRS and Medtronic file appellate briefs in Eighth Circuit appeal arguing for different transfer pricing methods (2024-1399) |
07.10.2024 | IRS representative says corporations that did not respond to transfer pricing compliance letters have been referred for possible examination (2024-1337) |
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06.28.2024 | US Treasury suspends key provisions of US-Russia Tax Treaty and Protocol, effective 16 August 2024 (2024-1294) |
06.26.2024 | U.S. Supreme Court holds mandatory repatriation tax is constitutional (2024-1260) |
06.05.2024 | District Court allows enforcement of IRS summons in transfer pricing audit of Eaton (2024-1136) |
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05.17.2024 | Proposed regulations would expand guidance on foreign trusts and large foreign gifts (2024-1008) |
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04.30.2024 | US Treasury finalizes regulations on domestically controlled QIEs, modifying the "domestic corporation look-through rule" and providing a transition rule for certain existing QIEs (2024-0885) |
04.30.2024 | Treasury Secretary Yellen appears before Ways & Means (2024-0887) |
04.15.2024 | Much-anticipated proposed regulations on stock repurchase excise tax follow earlier guidance with some modifications, including to funding rule, redemptions (2024-0786) |
04.03.2024 | Company disputes $2.7 billion transfer pricing charge by IRS (2024-0725) |
04.01.2024 | APA report for 2023 shows number of APAs executed more than doubled (2024-0714) |
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03.21.2024 | Senate Finance Committee holds hearing with Secretary Yellen (2024-0663) |
03.20.2024 | US IRS official discusses benefits of mandatory arbitration on MAP (2024-0637) |
03.15.2024 | US FY2025 Budget contains international tax proposals, mainly stemming from prior budgets (2024-0618) |
03.15.2024 | FY2025 budget proposes extending IRS statute of limitations on complex cases (2024-0620) |
03.12.2024 | IRS finalizes revised Form W-9 with new requirement for flow-through entities (2024-0584) |
03.12.2024 | IRS finalizes revised Form W-9 with new requirement for flow-through entities (2024-0584) |
03.07.2024 | Ways & Means Subpanel holds OECD Pillar One hearing (2024-0549) |
03.01.2024 | US IRS delays Form 1042 electronic filing requirement for US and foreign withholding agents (2024-0497) |
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02.12.2024 | United States | IRS sending out more letters regarding transfer pricing compliance (2024-0383) |
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01.30.2024 | Updated 2023 US IRC Section 1256 qualified board or exchange list (2024-0309) |
01.30.2024 | Updated US list of foreign currency futures contracts - starting point for IRC Section 1256 (2024-0310) |
01.29.2024 | User fee for advance pricing agreements increases effective February 2, 2024 (2024-0289) |
01.23.2024 | IRS signals new IRC Section 367(d) guidance in 2024 on repatriation of intangible property (2024-0255) |
01.22.2024 | South Carolina administrative court upholds forced combination as an equitable and reasonable alternative apportionment method for achieving fair representation of taxpayer's in-state activity (2024-0244) |
01.18.2024 | Abbott petitions Tax Court to redetermine deficiencies (2024-0221) |
01.17.2024 | Senate Budget Committee hearing focuses on international tax issues (2024-0219) |
01.08.2024 | United States | Notice 2024-16 provides that Section 961(c) basis of acquired CFCs carries over to domestic acquiring corporations in certain covered inbound transactions (2024-0141) |
01.05.2024 | US Treasury adds Chile to the list of treaty countries that meet the requirements of IRC Section 1(h)(11), removes Russia and Hungary (2024-0127) |
01.05.2024 | Generic Legal Advice Memorandum says IRS can consider implicit support to price intercompany loans (2024-0132) |