A weekly summary of the top weekly tax news, trends
and developments in the Americas

     This week's tax news from the Americas

• US IRS extends penalty relief for underpayment of estimated CAMT and issues CAMT proposed regulations
  In Notice 2024-66, the IRS has waived the penalty under IRC Section 6655 for a corporation's failure to pay estimated tax installments attributable to its alternative minimum tax (CAMT) liability under IRC Section 55 for any tax year that begins after 31 December 2023, and ends before 1 January 2025. At the same time, the IRS released the long-awaited CAMT proposed regulations (REG-112129-23), which propose rules regarding the application of the 15% CAMT on the adjusted financial statement income of large corporations.

• Colombian 2024 tax reform bill submitted to Congress, would affect corporate and capital gains rates, among others
  On 10 September 2024, the Colombian government submitted to the Congress a tax reform bill (Financial Law) aimed at covering a gap of approximately US$4b in the proposed 2025 budget law, which is also currently under discussion in the Congress. The 2024 tax reform bill proposes: (i) a progressive corporate income tax rate and a phased reduction of the marginal rate (35%); (ii) an increase in the minimum tax rate from 15% to 20%; and (iii) an increase in the capital gains tax rate from 15% to 20%.

• Peru postpones effective date to 1 December 2024 for applying 18% VAT on digital services
  Peru postponed from 1 October 2024 to 1 December 2024 the effective date for the 18% value-added tax (VAT) on digital services. Accordingly, beginning 1 December 2024, nonresident providers of digital services and sellers will be obliged to declare and pay an 18% VAT in Peru.

• Canada imposes surtaxes on imports of Chinese EVs, steel and aluminum products, considers surtaxes on critical manufacturing goods
  On 26 August 2024, Canada’s Department of Finance (Finance) announced that the government intends to implement a 100% surtax on all Chinese-made electric vehicles (EVs), effective 1 October 2024. In addition, the federal government intends to apply a 25% surtax on imports of steel and aluminum products from China, effective 15 October 2024. As part of the same announcement, Finance indicated that a consultation would be launched for other key sectors in the near term. On 10 September 2024, Finance announced a 30-day consultation period, from 10 September 2024 to 10 October 2024, on potential surtaxes in response to Chinese trade practices in critical manufacturing sectors related to EV production.

• USTR publishes final Notice of modification of actions on impacted Chinese origin products subject to increase in additional Section 301 tariffs and applicable exclusions
  On 13 September 2024, the United States Trade Representative (USTR) finalized its modification of actions relative to 14 product groups as either subject to an increase in Section 301 of the Trade Act of 1974 (Section 301) tariffs or eligible for exclusions based on conclusion of its four-year review. These modification actions respond to a USTR 28 May 2024 Notice (USTR May Notice), which covered 382 Harmonized Tariff Schedule of the United States (HTSUS) subheadings and 14 product groups with an approximate annual trade value of US$18b, including steel and aluminum, semiconductors, electric vehicles (EV), batteries, critical minerals, solar cells, ship-to-shore cranes, and medical products.

• US White House publishes Fact Sheet outlining proposed changes to de minimis shipments exemption
  On 13 September 2024, the Biden-Harris Administration published a Fact Sheet outlining its intent to publish two Notices of Proposed Rulemaking (NPR) and one Final Rule relating to de minimis shipments, which are shipments that are valued at US$800 or less and permitted to enter the United States without duties and taxes, and with less stringent import documentation, when imported by one person in one day. The NPRs would exclude certain shipments from the de minimis exemption, most notably those goods subject to the punitive 301 tariffs, and strengthen information collection requirements. The Final Rule would require importers of consumer products to electronically file Certificates of Compliance with US Customs and Border Protection and the Consumer Product Safety Commission at the time of entry, including for de minimis shipments.

     This week's newsletters

• Report on recent US international tax developments - 20 September 2024
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.
• Global Tax Policy and Controversy Watch | September 2024 edition
  EY's monthly report with highlights of the latest Global Tax Controversy developments.
• The Latest on BEPS and Beyond | September 2024
  EY's monthly report with brief summaries of the latest activity in the OECD Base Erosion and Profit Shifting (BEPS) project as well as country specific legislative and administrative activity, including global and regional policy trends related to the global focus on BEPS.
• PE Watch | Latest developments and trends, September 2024
  EY's monthly report with brief summaries of the latest permanent establishment activity and trends.

     Upcoming EY webcasts

• 24 September: Accounting for income taxes: a quarterly perspective - September 2024
• 26 September: What Q3 IFRS Quarterly Tax Developments could impact tax accounting
• 26 September: BorderCrossings . . . With EY transfer pricing and tax professionals
• 1 October: Practical CbCR considerations in the context of BEPS 2.0 Pillar Two

A calendar of all upcoming EY webcasts is available.

     Recent EY podcast

• EY Podcast | Weekly US international cross-border taxation news for week ending 20 September 2024

All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts.

      This week's EY Global Tax Alerts

      Americas

• Brazil facing delays in registration appointments for foreign employees and other foreign nationals
• Brazil now allows qualifying foreign students to apply for residence authorization for work purposes

     Africa

• Ethiopia introduces new VAT Proclamation introducing raft of changes
• Uganda issues Tax Amendment Acts for 2024

     Asia

• China introduces simplified visa application processes
• Taiwan announces proposal increasing AMT rate for certain MNEs from 12% to 15%

     Europe

• Netherlands budget proposals; key legislative developments for 2025
• Sweden | CJEU rules Swedish withholding tax on dividends to foreign public pension funds is contrary to free movement of capital
• UK announces statement of changes to immigration rules
• UK releases new Guidelines for Compliance | 'Help with common risks in transfer pricing approaches'

     Middle East

• Oman implements new restrictions on professions available to foreign nationals
• Saudi Arabia proposes amendments to VAT Implementing Regulations

     Oceania

• Australia introduces Privacy and Other Legislation Amendment Bill 2024

Additional resources

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About Americas Tax Roundup

Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C.
Jennifer Brittenham, writer and editor

Distributed weekly to all Americas Tax personnel.