20 January 2025

2024 Year in Review | Tax Alerts: U.S. International Tax

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.

 
Key U.S. international tax developments, 2024
 
01.17.2025Treasury finalizes regulations on review of federal tax controversies by IRS Appeals office (2025-0269)
01.10.2025Abbott petitions Tax Court to redetermine deficiencies for 2020 (2025-0195)
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12.19.2024IRS official confirms that IRS can apply economic substance doctrine to transfer pricing cases (2024-2345)
12.19.2024US 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)
12.19.2024US taxpayers may elect OECD's simplified and streamlined approach to intercompany transactions beginning in 2025 (2024-2351)
12.13.2024United States | Final and proposed regulations on qualified business units retain foreign exchange exposure pool method under Section 987, with simplifying elections (2024-2298)
12.06.2024Long-awaited US proposed regulations address certain PTEP complexities (2024-2229)
12.05.2024US | FinCEN continues to extend certain signature authority reporting (FBAR, Form 114) (2024-2218)
12.02.2024FIRST IMPRESSIONS | US Treasury and IRS propose long-awaited regulations on previously taxed earnings and profits of foreign corporations (2024-9006)
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11.25.2024OECD's 2023 mutual agreement procedure statistics show continued strength in the US program (2024-2149)
11.11.2024IRS representative indicates that corporations failing to respond to transfer pricing compliance letters have been referred for examination (2024-2067)
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10.25.2024Abbott files petition with Tax Court regarding deficiency determinations for 2017 and 2018 (2024-1960)
10.14.2024United States | Final IRC Section 367(d) regulations open door to intangible property repatriation for US multinationals (2024-1885)
10.08.2024IRS revenue ruling states that the European Energy Exchange is a "qualified board or exchange" under IRC Section 1256(g)(7)(C) (2024-1844)
10.04.2024San Francisco voters to decide on changes to the City's business taxes (2024-1825)
10.02.2024IRS 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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09.30.2024US IRS representatives say IRS will evaluate transfer pricing documentation and method when deciding on penalties (2024-1791)
09.25.2024Irish Tax Appeal Commission rules on treatment of stock-based compensation in services cost base transfer pricing dispute (2024-1765)
09.17.2024Sixth Circuit grants stay on enforcing IRS summons requesting foreign employee performance evaluations in transfer pricing audit (2024-1711)
09.13.2024US IRS issues penalty relief for failure to pay remaining estimated CAMT installments for 2024 (2024-1688)
09.10.2024US 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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08.23.2024US IRS issues new proposed regulations that limit or modify taxpayers' ability to make or revoke certain foreign currency elections (2024-1600)
08.11.2024United 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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07.30.2024US 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)
07.23.2024US Supreme Court overrules Chevron deference to agency regulations (2024-1432)
07.19.2024Final IRC Section 367(b) regulations address certain cross-border triangular reorganizations and inbound nonrecognition transactions (2024-1416)
07.18.2024IRS and Medtronic file appellate briefs in Eighth Circuit appeal arguing for different transfer pricing methods (2024-1399)
07.10.2024IRS representative says corporations that did not respond to transfer pricing compliance letters have been referred for possible examination (2024-1337)
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06.28.2024US Treasury suspends key provisions of US-Russia Tax Treaty and Protocol, effective 16 August 2024 (2024-1294)
06.26.2024U.S. Supreme Court holds mandatory repatriation tax is constitutional (2024-1260)
06.05.2024District Court allows enforcement of IRS summons in transfer pricing audit of Eaton (2024-1136)
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05.17.2024Proposed regulations would expand guidance on foreign trusts and large foreign gifts (2024-1008)
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04.30.2024US 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)
04.30.2024Treasury Secretary Yellen appears before Ways & Means (2024-0887)
04.15.2024Much-anticipated proposed regulations on stock repurchase excise tax follow earlier guidance with some modifications, including to funding rule, redemptions (2024-0786)
04.03.2024Company disputes $2.7 billion transfer pricing charge by IRS (2024-0725)
04.01.2024APA report for 2023 shows number of APAs executed more than doubled (2024-0714)
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03.21.2024Senate Finance Committee holds hearing with Secretary Yellen (2024-0663)
03.20.2024US IRS official discusses benefits of mandatory arbitration on MAP (2024-0637)
03.15.2024US FY2025 Budget contains international tax proposals, mainly stemming from prior budgets (2024-0618)
03.15.2024FY2025 budget proposes extending IRS statute of limitations on complex cases (2024-0620)
03.12.2024IRS finalizes revised Form W-9 with new requirement for flow-through entities (2024-0584)
03.12.2024IRS finalizes revised Form W-9 with new requirement for flow-through entities (2024-0584)
03.07.2024Ways & Means Subpanel holds OECD Pillar One hearing (2024-0549)
03.01.2024US IRS delays Form 1042 electronic filing requirement for US and foreign withholding agents (2024-0497)
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02.12.2024United States | IRS sending out more letters regarding transfer pricing compliance (2024-0383)
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01.30.2024Updated 2023 US IRC Section 1256 qualified board or exchange list (2024-0309)
01.30.2024Updated US list of foreign currency futures contracts - starting point for IRC Section 1256 (2024-0310)
01.29.2024User fee for advance pricing agreements increases effective February 2, 2024 (2024-0289)
01.23.2024IRS signals new IRC Section 367(d) guidance in 2024 on repatriation of intangible property (2024-0255)
01.22.2024South 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)
01.18.2024Abbott petitions Tax Court to redetermine deficiencies (2024-0221)
01.17.2024Senate Budget Committee hearing focuses on international tax issues (2024-0219)
01.08.2024United 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)
01.05.2024US 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)
01.05.2024Generic Legal Advice Memorandum says IRS can consider implicit support to price intercompany loans (2024-0132)

Document ID: 2025-0007