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.

Related topics Tax

This edition of the ITS Washington Dispatch for January 2020 looks at the latest insights provided by US government officials on the new guidance resulting from the Tax Cuts and Jobs Act. It also takes a look at the believed deal between the US and France over France’s DST, and potential issues still with the UK and Italy.

It covers various regulations finalized by the IRS on contributing appreciated property to partnerships with foreign partners, FATCA rules and cryptocurrency accounts, as well as guidance on double taxation exemption under Section 965 repatriation.

This EY monthly update covers the new insights from the US government related to the upcoming tax guidance, following the Tax Cuts and Jobs Act. Officials have been quoted on timelines for giving new guidance for both domestic and lower tier foreign organizations.

The dispute between the US and France over France’s DST is covered, including beliefs that an agreement has been reached. The UK and Italy could still face retaliatory tariffs if they continue with their own DST plans.

The IRS has finalized regulations that deny non-recognition treatment to contributions of appreciated property by US persons to certain partnerships with foreign partners. These regulations provide that the rule Section 721A does not apply unless other specific requirements are met.

Final Foreign Account Tax Compliance Act (FATCA) and chapter 3 of the Internal Revenue Code regulations have been issued, finalizing some of the provisions included in the proposed regulations. These generally provide US and non-US holding agents to identify payees and their FATCA status.

An IRS official has been quoted as saying the IRS will entertain issuing Private Letter Rulings (PLRs) in the cryptocurrency space to address issues not covered in the cryptocurrency guidance issued in October 2019. Taxpayers interested in entering a PLR should contact the IRS.

Finally, the IRS will consider requests for double taxation relief due to Section 965 repatriation tax in certain circumstances, and the OECD has announced members of the Inclusive Framework in BEPS 2.0 will reach a consensus on new rules by the end of 2020.

Learning outcomes

  • Understanding the latest insights provided on upcoming tax guidance
  • Finding out the latest in the DST disagreements between the US and France, the UK and Italy
  • Understanding the latest provisions from the IRS for individuals looking to transfer appreciated property to foreign partners, for taxpayers wishing to file cryptocurrency, and for business concerned about double taxation
  • Getting updates from the OECD on the BEPS 2.0 project and Inclusive Framework consensus for international tax rules

Podcast

Episode 3

Duration 16m 38s

In this series

Series overview
(Event List - Manual)

International Tax Services Washington Dispatch, March 2020

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Episode 1

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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.
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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.
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Episode 3

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