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

EY offices are closed from 23 December  to 1 January, 2025. The next Americas Tax Roundup will be published on 6 January 2025. 

     This week's tax news from the Americas

• United States | Final and proposed regulations on qualified business units retain foreign exchange exposure pool method under IRC Section 987, with simplifying elections
  On 11 December 2024, the US IRS and Treasury Department published final regulations (TD 10016) under IRC Section 987 on determining the taxable income or loss and currency gain or loss for a qualified business unit whose functional currency differs from its tax owner. The IRS and Treasury Department also published proposed regulations (REG-117213-24), which provide an election to simplify the computation of unrecognized IRC Section 987 gain or loss on certain recurring transactions.

• Canada | Digital platform operators' first information return due by 31 January 2025
  Digital platform operators in Canada must file an information return with the required information on reportable sellers no later than 31 January of the year following the calendar year in which a seller is identified as a reportable seller. As such, the first information returns are due by 31 January 2025 for the 2024 calendar year.

• Canada issues Federal Fall Economic Statement 2024
  On 16 December 2024, Canada’s Government House Leader Karina Gould tabled the federal government's Fall Economic Statement 2024(FES). The FES contains several tax measures affecting individuals and corporations, including various proposed enhancements to the scientific research and experimental development (SR&ED) tax incentive program (see Tax Alert 2024-2330 for additional details on the SR&ED tax incentive program).

• US Trade Representative announces tariff increases on certain Chinese-origin tungsten products, wafers and polysilicon
  On 11 December 2024, the United States Trade Representative announced modifications to increase tariff rates on certain tungsten products, wafers and polysilicon of Chinese origin. The modifications include increasing tariffs to 25% on three tungsten product subheadings and to 50% on two subheadings for wafers and polysilicon, effective 1 January 2025.

• Norway and US agree qualifying RICs aren't restricted from double tax treaty benefits
  The competent authorities in the United States (US) and Norway signed a Competent Authorities Agreement (CAA), agreeing that qualifying regulated investment companies (RICs) under IRC Sections 851 and 852 are not restricted from treaty benefits under Article 20 of the US-Norway Double Tax Treaty (DTT). This effectively means that RICs may claim treaty benefits under the DTT, including a reduction of dividend withholding tax to 15%.

     This week's newsletters

• Report on recent US international tax developments - 20 December 2024
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.

• EY TradeWatch - 12 December 2024
  Our regular newsletter provides information about customs and international trade developments to help you develop strategies to manage duty costs and the risks of global trade, to improve trade compliance and to increase the operational effectiveness of international supply chains.

• PE Watch - 12 December 2024
  Our monthly report with brief summaries of the latest permanent establishment activity and trends.

• The Latest on BEPS and Beyond - 13 December 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.

• Trade Talking Points - 13 December 2024
  Our monthly report with the latest insights from EY's Trade Strategy team.

     Upcoming EY webcasts

• 21 January: GenAI for Legal: How to move from proof of concept to production
• 24 January: Tax in a time of transition: Legislative, economic, regulatory and IRS developments

A calendar of all upcoming EY webcasts is available.

     Recent EY podcasts

• EY Podcast | Weekly US international cross-border taxation news for week ending 20 December 2024
• EY talks tax | 2024 Asset management tax year-end webcast - 9 December 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

• US Department of Homeland Security publishes H-1B Modernization Rule

     Africa

• South Sudan enacts Financial Act 2024/2025

     Asia

• China introduces new digital combined work permit and social security card
• China updates visa-free transit policy for certain foreign nationals
• Korea extends Temporary Electronic Travel Authorization exemption until 31 December 2025
• Vietnam introduces new and amended tax laws on foreign suppliers conducting business through e-commerce and digital platforms

     Europe

• Bulgaria's 2025 State Budget Act introduces Standard Audit File for Tax (SAF-T) requirement
• Bulgaria and Romania to become full Schengen members effective 1 January 2025
• Cyprus introduces Global Minimum Tax for MNE groups and large-scale domestic groups
• European Commission announces €4.6b for decarbonization, EV batteries and hydrogen
• European Commission proposes a gradual implementation of the Entry and Exit System
• French Parliament approves Special Finance Bill for 2025
• German Federal Ministry of Finance publishes final decree regarding the application of anti-hybrid rules
• Germany renews rules for permits under the Temporary Protection Directive
• Gibraltar publishes proposed legislation for Pillar Two, including Qualified Domestic Top-up Tax
• Luxembourg adopts various measures reducing individuals' tax burden
• Luxembourg Parliament enacts corporate income tax reduction and other changes affecting corporate taxpayers
• Luxembourg Parliament enacts changes to Pillar Two Law
• Mercosur-European Union trade agreement negotiations conclude
• Netherlands publishes Amount B Decree
• UK joins Comprehensive and Progressive Agreement for Trans-Pacific Partnership — implications for businesses

     Middle East

• Egypt issues law reintroducing tax dispute resolution provisions
• Israel to launch Electronic Travel Authorization system effective 1 January 2025

     Oceania

• Australia issues specified jurisdictions for public country-by-country reporting regime

Additional resources

Comments. If you have any questions or suggestions about this newsletter, please email Tax News Update Help at: ustaxalertshelp@ey.com.

About Americas Tax Roundup

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

Distributed weekly to all Americas Tax personnel.