A monthly review of US international tax-related developments. In this edition:

President Biden delivers State of the Union; releases FY2025 Budget with international tax proposals – Congress passes final FY2024 funding bills, tax bill in limbo – Treasury Secretary defends Administration’s BEPS position at Senate hearing – House Ways & Means Subpanel holds OECD BEPS Pillar One hearing – IRS delays Form 1042 electronic filing requirement for US and foreign W/H agents – US officials offer international regulatory update – IRS will no longer issue single-issue PLRs, instead focus on ‘transactional rulings’ – IRS official discusses benefits of MAP mandatory arbitration – OECD releases update on BEPS 2.0 project – OECD Council approves update to Model commentary on exchange of information.

A monthly review of US international tax-related developments. In this edition:

OECD releases final guidance on BEPS Pillar One Amount B on baseline distribution – Finalization of proposed FX regulations expected by year end, two sets of proposed Section 367 regs in first half of 2024 – US Senate approves IRS Chief Counsel nomination – IRS sending more letters regarding transfer pricing compliance – OECD releases 2024 update on peer reviews under BEPS Action 5 on harmful tax practices.

A monthly review of US international tax-related developments. In this edition:

US House passes tax package, Senate action uncertain – Congress approves CR to fund government until early March 2024 – IRS signals new Section 367(d) guidance in 2024 on repatriation of IP – US officials provide regulatory update – IRS announces cryptocurrency transactions do not need to be reported until regulations issued – User fee for APAs increase, effective 2 February 2024 – US official offers BEPS Pillar One insights – OECD releases updated estimates of the economic impact of BEPS Pillar Two.