Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

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


The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


Copyright © 2024, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more