Ey Cross-border Taxation Alerts

On 30 October 2013, Law 16/2013 was published in the Spanish Official Gazette; it introduces relevant amendments to Spanish corporate income tax and extends the application of certain measures to FY 2014 and 2015.

A review of the week's major US international tax-related news. In this edition: House-Senate conference committee holds first meeting - Senate Finance Committee to release tax reform drafts in coming weeks - IRS issues Notice 2013-69 on FATCA - US, Hungary initial FATCA Model 1 IGA -- Mexican Congress approves tax reform

A review of the week's major US international tax-related news. In this edition: IRS rules certain growing activities qualify as production for subpart F foreign base company sales income rules -- ILM 201340016 considers triangular C reorg completed before release of Notice 2006-85 -- Update on Ireland's change to the Irish tax residency rules.

India’s Central Board of Direct Taxes (CBDT) recently issued a notification for application of General Anti-avoidance Rules (GAAR).

Mexico’s lower House of Congress revised and approved the proposed tax reform on 18 October 2013; it now moves on to the Senate for debate and vote.

A review of the week's major US international tax-related news. In this edition: Congress approves funding / debt bill; government reopens -- Ireland proposes change to tax residency rule to prevent "stateless" entities -- Italian Law Decree includes changes of interest to MNCs.

A review of the week's major US international tax-related news. In this edition: Movement on US fiscal impasse -- OECD country-by-country reporting may begin as early as 2014.

On 3 October 2013, the OECD published a memorandum seeking input on the development of an approach for country-by-country reporting of income, taxes paid, and economic activity.

An EY review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House; US opposes "virtual PE" concept and more.

A review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House -- US opposes "virtual PE" concept -- IRS concerned re: taxpayers unwinding so-called "sandwich structures" -- Two courts address STARS transactions.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans may tie movement on tax reform to legislation to raise the debt limit - Tax Court rules in BMC Software that accounts set up from Section 482 adjustment are related party indebtedness for Section 965 DRD.

In an opinion dated 6 September 2013, the European Council’s lawyers concluded that the proposed Financial Transaction Tax counterparty rule is contrary to EU law.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess; no progress on fiscal issues -- IRS CCA looks at interest expense allocation / apportionment for FTC purposes -- Prop. regulations issued on limitations on importation of net built-in losses; international tax implications.

On 8 September 2013, Mexico’s President Pena Nieto presented the long-awaited tax reform proposal to the Mexican Congress.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess to looming fiscal deadlines -- IRS issues final 901 regulations -- Final, temporary, and proposed regulations on application of straddle rules to debt instruments released.

A review of the week's major US international tax-related news. In this edition: US tax reform update -- IRS CCA concludes interest deductions on payments by US corporation to foreign parent disallowed under Section 267(a)(3) .

A review of the week's major US international tax-related news. In this edition: House and Senate committees continue work on tax reform during August recess -- IRS announces FATCA registration site available online.

A review of the week's major US international tax-related news. In this edition: US, Cayman Islands sign FATCA Model 1 IGA and TIEA -- IRS releases draft Form 8966 FATCA Report -- IRS releases PLR 201332007; addresses subpart F foreign base company sales branch rules.

A review of the week's major US international tax-related news. In this edition: A review of the status of US tax reform -- US, Belgium sign Competent Authority Agreement -- Urgent action by US and foreign MNCs may be required due to new Canadian upstream loan rules.

The Italian Revenue Agency issued its annual guidelines for Revenue auditors on goals to achieve and tax strategies to pursue in the carrying out of FY 2013 audit activities.