Global Tax Alert | 15 August 2013

US Treasury and IRS 2013-2014 Priority Guidance Plan contains ongoing and new international tax projects

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On 9 August 2013, the US Treasury Department and IRS released the 2013-2014 Priority Guidance Plan (the Plan). The Plan provides an overview of the issues that Treasury and the IRS intend to address over the period ending 30 June 2014. As in prior years, Treasury and the IRS state that they will update and reissue the Plan periodically to reflect additional guidance that they intend to publish, to allow for consideration of comments received from taxpayers and practitioners on additional projects, and to respond to developments arising during the plan year. The Plan also indicates items that have already been published.

The Plan includes 46 international tax projects, four fewer than the 2012-2013 Priority Guidance Plan. Only one of the identified international projects on the Plan is new, the rest of the international projects are carried over from the 2012-2013 Priority Guidance Plan with a few minor revisions in the scope of some of the projects. The new project relates to final regulations on the treatment of upfront payments on swaps under Section 956.

In addition, three projects that were included in the 2012-2013 Priority Guidance Plan are dropped from this year's Plan without issuance of any guidance. Those projects are:

  • Guidance under Section 960(c) on the amount of foreign taxes deemed paid with respect to Section 956 inclusions;
  • Regulations under Section 861 on the source of event basis compensation; and
  • Notice under Section 877A supplementing Notice 2009-85.

For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP, International Tax Services, Washington, DC
  • Margaret O'Connor
    +1 202 327 6229
  • Jose Murillo
    +1 202 327 6044
  • Yuelin Lee
    +1 202 327 6378

EYG no. CM3732