EY Cross-Border Taxation Spotlight for Week ending 26 August 2022

A review of the week's major US international tax-related news. In this edition: IRS to delay effective date for aspects of Section 871(m) regulations, further extend transition relief – IRS extends deadline for unfiled 2019 and 2020 returns, penalty relief for certain 2019 and 2020 returns – US Tax Court increases Medtronic royalty rate under unspecified TP method.