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On 22 March 2024, Treasury proposed regulations identifying exceptions to the 45-day advance notice period that the IRS must provide taxpayers before contacting third parties during audit. The Taxpayer First Act (2019) made several structural changes to the IRS and the Code that—in theory—establish some degree of equilibrium in the audit process and protect taxpayers from (real or perceived) process-related abuses.
One such change was requiring the IRS to provide taxpayers substantive, advance notice before contacting third parties for information during an exam.

On 14 November 2023, the IRS issued the long-awaited proposed implementing regulations (REG-142338-07) under section 4966, added by the Pension Protection Act of 2006 (“Proposed Regulations”). The Proposed Regulations address many definitions related to donor advised funds, donors and donor advisors. The proposed regulations are intended to help taxpayers understand how the imposition of excise taxes on taxable distributions may apply to them.

On 6 May 2024, Decree No. 385/2024 was published in the Official Gazette, extending the scope of the Impuesto PAÍS (“PAIS Tax”) to include the acquisition of foreign currency to distribute profits and dividends, as well as to repatriate nonresidents’ portfolio investments, generated from payments received in Argentina for these concepts from 1 September 2019. In addition, the tax will also apply to the subscription of BOPREAL bonds for the previous purposes.

On 2 May 2024, Decree No. 378/2024 was published in the Official Gazette, extending the deadline for repatriating financial assets of at least 5% of the total value of the assets located abroad until and including 31 May 2024.
As a reminder, the applicable Personal Assets Tax (PAT) rates for assets located abroad will be the same as those applicable to assets located in Argentina if taxpayers repatriate financial assets of at least 5% of the total value of the assets located abroad before 31 March of each year and if certain additional requirements are met.

The latest edition of our Field Guide to Going Global helps you examine foreign law issues for taking business models, products and technology international. Our guidance should be helpful whether you are working for a start-up company or a large multinational enterprise that is broaching new frontiers.

On 26 March 2024, the IRS Advance Pricing and Mutual Agreement (APMA) Program issued their 25th annual Advance Pricing Agreement (APA) report describing the experience, structure, and activities of the APMA Program during calendar year 2023. The report provides statistical information about the numbers of APA applications received and resolved during the year, including countries involved and transfer pricing methods employed. This article identifies key takeaways based on the data from the report and our experience advising companies during the APA process.

The Colombian Tax Office (“DIAN”) and the Superintendence of Companies have entered into an inter-administrative agreement for the exchange of information related to the Ultimate Beneficial Owner Registry, to strengthen the inspection and control functions of these entities and their investigative powers.

On 1 January 2022, the CFC rules became effective in Ukraine. For the novelty of the concept and the imperfections of the underlying legislation, many provisions of the applicable CFC rules call for clarification, elaboration, or further guidance.
In this context, on 2 May 2023, the Parliament of Ukraine passed – in the first (of typically two) readings – Bill No. 8137 “On Amendments to the Tax Code of Ukraine with respect to Enhancement of the Taxation of Controlled Foreign Companies” (“Amending Bill”), aimed at addressing most pressing issues pertaining to the application and interpretation of the CFC rules.