International Tax Services Washington Dispatch, November 2019

In this episode, our ITS team focuses on the OECD’s public consultation document on Pillar Two of the global anti-base erosion proposal.

Related topics Tax

This edition of the ITS Washington Dispatch for November focuses on the OECD’s public consultation document on Pillar Two of the global anti-base erosion proposal and the aims to bring about global standards for international trade as the economy is digitalized. It also covers IRS announcements into ownership attribution rules for CFC purposes and a new Section 965 compliance campaign.

There’s news on Altera Corporation’s appeal for a rehearing in their cost sharing case, and further updates from the OECD on Pillar One, a new database on individual multinationals, and CbC reporting, as all the latest developments in US and international tax are covered.

This EY monthly update starts with the release of the highly anticipated OECD public consultation document on the global anti-base erosion proposal under Pillar Two, of the ongoing project titled Addressing the Tax Challenges of the Digitalization of the Economy. In summary, the project aims to ensure companies that operate internationally are subject to an established minimum tax rate. Key rules are being established between members to regulate other areas of international trade.

The IRS made several announcements, including final regulations on attributing ownership of stock and other interests, to determine whether a person is considered a related person with respect to foreign corporations. The other major announcement was a campaign to ensure compliance in Section 965 transition tax.

The Treasury has announced that international guidance on Tax Cuts and Jobs Act would be issued imminently, while the government has acknowledged that transfer pricing could be used to reduce liability, but adjustments can be made to compensate in future.

The Altera Corporation has had a request for an en banc rehearing rejected by the Ninth Circuit, with regards to their case on cost sharing. They have accused the government of employing bait and switch tactics.

Further announcements from the OECD include a public consultation to be held on Pillar One, a release of a new Analytical Database on Individual Multinationals and Affiliates (ADIMA), and further guidance on CbC reporting and the spontaneous exchange of information by nominal tax jurisdictions.

Learning outcomes

  • Understanding the latest developments from the OECD regarding both Pillar Two’s public consultation, the current consultation on Pillar One and other updates
  • Finding out about the new IRS announcements including regulations on ownership attribution with regards stock, and a new campaign on Section 965 transition tax
  • Learning about the latest Tax and Job Cuts guidance from the Treasury
  • Discovering the outcome of Altera Corporation’s request to the Ninth Council for an en banc rehearing in their cost sharing case

Podcast

Episode 5

Duration 15m 24s

In this series

Series overview
(Event List - Manual)

International Tax Services Washington Dispatch, March 2020

In this episode, our ITS team summarizes key developments in the US for the month including the response to the COVID-19 pandemic.
Podcast

Episode 1

Duration
13m 49s

Presenters

International Tax Services Washington Dispatch, February 2020

In this episode, our ITS team details the confirmation that the US and France have agreed to de-escalate tensions over France’s DST.
Podcast

Episode 2

Duration
13m 30s

Presenters

International Tax Services Washington Dispatch, January 2020

In this episode, our ITS team provides a review of major US and international tax related news for the month of January 2020.
Podcast

Episode 3

Duration
16m 38s

Presenters

International Tax Services Washington Dispatch, December 2019

In this episode, our ITS team reviews the escalating tensions between the US and France, related to the trade investigations into France’s Digital Services.
Podcast

Episode 4

Duration
23m 40s

Presenters

International Tax Services Washington Dispatch, November 2019

In this episode, our ITS team focuses on the OECD’s public consultation document on Pillar Two of the global anti-base erosion proposal.
Podcast

Episode 5

Duration
15m 24s

Presenters

International Tax Services Washington Dispatch, October 2019

In this episode, our ITS team looks at the OECD public consultation document regarding Pillar One of the BEPS 2.0 project.
Podcast

Episode 6

Duration
20m 52s

Presenters

International Tax Services Washington Dispatch, September 2019

In this episode, our ITS team looks at the entry-into-force dates of tax protocols between the US and Japan, Spain, Luxembourg and Switzerland.
Podcast

Episode 7

Duration
13m 57s

Presenters

International Tax Services Washington Dispatch, August 2019

In this episode, our ITS team focuses on digital tax issues, the digital revolution, and the tax implications of a digital system.
Podcast

Episode 8

Duration
16m 13s

Presenters