A weekly summary of the top weekly tax news, trends
and developments in the Americas

     This week's tax news from the Americas

• Brazil approves supplementary law, taking a big step toward Brazilian tax reform
  After many months of discussion, Brazil’s Congress approved one of the supplementary laws that would regulate new taxes under the Brazilian tax reform. The new law paves the way for introducing the tax on goods and the contribution on goods and services in 2026.

• US taxpayers may elect simplified and streamlined approach to intercompany transactions beginning in 2025
  In Notice 2025-04 (Notice), the Treasury Department and IRS announced their intent to issue proposed regulations and other guidance on applying the simplified and streamlined approach (SSA) of the Organisation for Economic Co-operation and Development for pricing certain controlled transactions involving baseline marketing and distribution activities. Taxpayers subject to US tax on in-scope transactions may rely on the Notice and elect to apply the SSA for tax years beginning on or after 1 January 2025.

• Brazilian Congress approves Bill of Law introducing OECD Pillar Two rules
  On 18 December 2024, the Brazilian Congress approved Bill of Law 3,817, which implements Pillar Two rules in the country. The Bill of Law introduces a qualified domestic minimum top-up tax (QDMTT) but does not include the income inclusion rule (IIR) or the undertaxed payments rule (UTPR). The Brazilian QDMTT rules largely align with the global anti-base erosion (GloBE) model rules and are scheduled to take effect for fiscal years starting on or after 1 January 2025.

• 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
  In Paul Bruyea v. United States, the US Court of Federal Claims held that an individual could claim a treaty-based foreign tax credit under the US-Canada Income Tax Treaty to offset the net investment income tax paid to the United States under IRC Section 1411.

• OECD releases fact sheet and automated tool for Pillar One Amount B
  On 20 December 2024, the Organisation for Economic Co-operation and Development released a “fact sheet” that explains, step-by-step, the application of Amount B and an “automated tool” for pricing the return on sales for baseline distribution activities under Amount B. Both are available on a new “Pillar One – Amount B” website (Pillar One – Amount B | OECD).

     This week's newsletters

• Report on recent US international tax developments - 3 January 2025
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.

     Upcoming EY webcasts

• 8 January: Proposed regulations on previously taxed earnings and profits: What the new guidance may mean for recent and longstanding questions
• 9 January: Sustainability Tax webcast series: Circularity and tax function strategy (Replay)
• 10 January: Final and proposed regulations under Section 987
• 21 January: GenAI for Legal: How to move from proof of concept to production
• 24 January: Tax in a time of transition: Legislative, economic, regulatory and IRS developments

A calendar of all upcoming EY webcasts is available.

     Recent EY podcasts

• EY Podcast | Weekly US international cross-border taxation news for week ending 3 January 2024

All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts.

 
     This week's EY Global Tax Alerts

     Americas

• Venezuelan nationals now eligible for two-year visas to regularize their status in Colombia

     Africa

• Nigeria issues Guidelines on Advance Pricing Agreements

     Asia

• China updates visa-free transit policy for certain foreign nationals
• Vietnam introduces new and amended tax laws on foreign suppliers conducting business through e-commerce and digital platforms

     Europe

• Denmark introduces new rules on taxation of dividends paid to resident and nonresident companies
• Denmark to revise application processing fees, salary requirements and Positive Lists effective 1 January 2025
• Italy introduces new obligations for tax representatives and represented entities

     Middle East

• Saudi Arabia temporarily extends grace period for foreign workers to regularize their stay

Additional resources

Comments. If you have any questions or suggestions about this newsletter, please email Tax News Update Help at: ustaxalertshelp@ey.com.

About Americas Tax Roundup

Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C.
Jennifer Mannetta, writer and editor

Distributed weekly to all Americas Tax personnel.