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| A weekly summary of the top weekly tax news, trends and developments in the Americas | |
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| This week's tax news from the Americas - 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.
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| This week's newsletters | | |
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| Upcoming EY webcasts A calendar of all upcoming EY webcasts is available. | | |
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| Recent EY podcasts All episodes of the EY Cross-Border Taxation Spotlight and EY Talks Tax are available through Apple podcasts. | | |
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| This week's EY Global Tax Alerts Americas Africa Asia Europe Middle East | | |
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| 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. | |
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