Treasury Aiming for Research Credit Fix in Pillar 2 Guidance 
March 25, 2024 – The United States is working to protect the benefits of the research credit under pillar 2 global minimum tax, possibly through OECD administrative guidance, a top Treasury official said. “We’re trying to come up with a kind of a range of potential fixes,” Scott Levine, acting Treasury deputy assistant secretary for international tax affairs, said March 19 at the Tax Executives Institute’s midyear conference in Washington, adding that Treasury is open to speaking with stakeholders about the issue.
Stephanie Soong, Tax Notes International

Werfel to Big Business: IRS Is Not Your Enemy 
March 25, 2024 – IRS Commissioner Daniel Werfel sought to allay corporate fears over the agency’s drive to increase audits on large businesses by claiming the heightened scrutiny will create a fair playing field for those who are compliant. Speaking at a Tax Executives Institute conference March 18, Werfel tried to draw a distinction between President Biden’s push for higher corporate tax rates and the IRS’s plan to step up enforcement efforts to go after large corporations.
Alexander Rifaat, Tax Notes Federal

Treasury Official Previews Guidance on Buyback Tax, Corporate AMT 
March 25, 2024 – Forthcoming proposed rules for the 1 percent stock buyback tax and corporate alternative minimum tax are weeks and months away, respectively, according to a Treasury official. Proposed rules for the buyback tax, enacted in August 2022 as part of the Inflation Reduction Act, “are very far along in clearance, the final stage of review for regulations,” Treasury Tax Legislative Counsel Krishna Vallabhaneni said March 18 at a Tax Executives Institute conference.
Chandra Wallace, Tax Notes Federal

Timing of Guidance for Research Amortization Still in Question 
March 25, 2024 – It isn’t clear how long proposed research amortization regulations will be delayed if Congress passes its retroactive relief proposal, according to Scott Vance, IRS associate chief counsel (income tax and accounting).
Nathan J. Richman, Tax Notes Federal

GILTI Figures Into CFC Applicability Project, Official Says  (subscription required for access)
March 19, 2024 – The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.
David Van den Berg, Law360 Tax Authority

Treasury Eyes Guidance to Address US R&D, Global Tax Interaction
March 19, 2024 – The US wants to change how its research and development credit is accounted for under the global minimum tax rules through OECD administrative guidance, following business concerns the incentive will cause companies to fall under the levy’s 15% threshold.
Lauren Vella, Daily Tax Report, Bloomberg Tax

Treasury Mulling Whether To Keep Foreign Tax Credit Regime  (subscription required for access)
March 18, 2024 – The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.
Natalie Olivo, Law360 Tax Authority

Werfel Calls Online Biz Account Authentication A Challenge  (subscription required for access)
March 18, 2024 – Establishing an effective user authentication method for companies using online business tax accounts is a challenge for the Internal Revenue Service and the agency wants suggestions on how to do it, commissioner Daniel Werfel said Monday.
David Van den Berg, Law360 Tax Authority

Treasury Proposed Stock Buyback Tax Rules in Final Review Stages
March 18, 2024 – The Treasury Department and IRS plan to drop a long-awaited proposed guidance package for the 1% stock repurchase excise tax in the coming weeks, after pushing back the release for months.
Caleb Harshberger, Daily Tax Report, Bloomberg Tax

IRS Aims to Finalize Foreign Currency Gains Rules This Year
March 18, 2024 – The IRS is working to finalize regulations this year on how a company’s subsidiary calculates its foreign-currency gains and losses, a Treasury Department official said Monday.
Erin Schilling, Daily Tax Report, Bloomberg Tax  

Treasury Mulling a New Foreign Tax Credit Rule Framework
March 18, 2024 – The Treasury Department is still mulling how to tweak final foreign tax credit regulations that are currently on hold following companies’ and tax practitioners’ concerns about compliance, a Treasury official said Monday.
Lauren Vella, Daily Tax Report, Bloomberg Tax  

IRS is Working on Relief For Penalties From Timely Filed Forms
March 18, 2024 – The IRS’s Large Business and International Division is considering relief for taxpayers who mail certain forms on time and still get an automatic penalty notice, an IRS official said Monday.
Erin Slowey, Daily Tax Report, Bloomberg Tax