August 18, 2023
Report on recent US international tax developments — 18 August 2023
The IRS recently announced that taxpayers that are not under examination will now have a better option to electronically request relief for certain late-filed international documents and forms. The new option, part of the IRS's paperless processing initiative, will allow for eFax filings and will apply to Relief for Gain Recognition Agreements, Late Filing Relief for Dual Consolidated Losses, and Relief for Partnership Gain Deferral Contributions.
A Treasury Financial Crimes Enforcement Network (FinCEN) rule that would extend the beneficial ownership information reporting deadline for reporting companies created or registered in 2024 is closer to release. The proposed rule that would extend the deadline was sent on to the OMB's Office of Information and Regulatory Affairs (OIRA) for review on 14 August, according to the OIRA website. Details of the extended deadline are not yet available. According to the summary of the disclosure rules released in 2022, reporting of certain information about beneficial ownership is intended to help prevent and combat certain activity such as money laundering and tax fraud. The final rule on beneficial ownership information reporting requirements is available here.
The OECD Director of the Centre for Tax Policy and Administration said this week that certain open issues related to Amount A in Pillar One (new nexus/taxing right) in the upcoming Multilateral Convention (MLC) are expected to be resolved by early fall. Manal Corwin said during a public podcast that "there are a small number of discrete technical points that involve a few jurisdictions, and when those are resolved, that will put us in a position to then finalize the text of the MLC."
For additional information with respect to this Alert, please contact the following:
Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC
Published by NTD's Tax Technical Knowledge Services group; Carolyn Wright, legal editor