In this episode, our ITS team focuses on the OECD’s public consultation document on Pillar Two of the global anti-base erosion proposal.
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.
- 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
Duration 15m 24s
In this seriesSeries overview