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

April 5, 2024
2024-0742

Report on recent US international tax developments — 5 April 2024

Congress returns to Washington next week from its two-week spring recess. It is still uncertain whether — or when — there will be Senate consideration of the Tax Relief for American Families and Workers Act (H.R. 7024) business tax and Child Tax Credit (CTC) expansion bill, which passed the House on 31 January and has remained in limbo since then. There was no reported movement on the bill over the two-week recess.

The IRS Advance Pricing and Mutual Agreement Program (APMA) issued the 25th annual Advance Pricing Agreement (APA) report (the Report) on 30 March in Announcement 2024-16. The Report discusses the APMA, including its activities and structure for calendar year 2023 and gives useful insights into its operation. According to the Report, the total number of APAs executed increased significantly from 77 to 156 and the median amount of time to finalize an APA decreased from 43.4 months in 2022 to 42 months in 2023. However, the number of APA filings slightly decreased in 2023, with taxpayers filing 167 APA requests (down from 183 in 2022). At year-end, 558 APA requests were pending (480 bilateral, 34 multilateral and 44 unilateral), down slightly from 2022. A Global Tax Alert provides details on the Report.

It is worth noting that the APMA has reportedly been working to update Revenue Procedure 2015-41 (and its MAP corollary Revenue Procedure 2015-40). The APMA has not indicated that there will be a comment period or a flexible implementation period. As a result, taxpayers considering an APA may want to submit their request before new guidance is issued.

The OECD did not meet the self-imposed BEPS Pillar One deadline to finalize the text of the multilateral convention (MLC) on Amount A by the end of March 2024. According to a recent report, negotiations regarding the global tax treaty are ongoing. An OECD official was quoted this week as saying that treaty talks "continue to move forward constructively." The plan has been for the OECD to hold a treaty signing ceremony by the end of June 2024.

* * * * * * * * * *
Contact Information

For additional information concerning this Alert, please contact:

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 ey.com. Please refer to the privacy notice/policy on these sites for more information.


Yes, I accept         Find out more