EY ITS Washington Dispatch, January 2020

02/05/20 • 16 min

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US officials offer new insights for coming international tax guidance – IRS releases final regulations on US partner contributions to partnerships with related foreign partners – Final FATCA and chapter 3 regulations issued – IRS will entertain cryptocurrency PLRs – IRS will consider certain requests for double taxation relief due to Section 965 repatriation – IRS rules target’s capitalized transaction costs do not create a separate and distinct intangible asset – OECD announces renewed IF commitment for 2020 consensus on new international tax rules under BEPS 2.0 – OECD releases additional guidance on CbCR, summary of related notification requirements – OECD releases third peer review report on Action 5 on the exchange of tax rulings.

Previous Episode

EY ITS Washington Dispatch, December 2019

In this edition: US releases USTR findings re France’s DST – US issues final and proposed BEAT regulations – IRS issues final and proposed FTC regulations – IRS issues final W/H and reporting regulations – IRS issues final Section 871(m) regulations on dividend equivalent payments, extends transition relief – IRS issues proposed regs on sourcing income from sales of certain personal property – IRS again delays certain Section 987 FX regulations – Treasury grants another FBAR extension – Officials discuss OECD BEPS 2.0 Project – OECD hosts Pillar 2 GloBE public consultation – OECD releases additional CbC guidance – OECD releases BEPS Action 14 peer review reports.

Next Episode

EY ITS Washington Dispatch, February 2020

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary confirms DST deal with France – All major TCJA guidance expected by October 2020 – Pending US tax treaties with Chile, Hungary and Poland may require renegotiation over BEAT – IRS officials elaborate on limited Section 965 transition relief, BEAT PLR option – Altera files for certiorari in US Supreme Court in cost sharing case – OECD on track to complete BEPS 2.0 core principles in 2020 -- OECD offers tax revenue estimates for BEPS 2.0 proposals – OECD issues CbCR consultation document – OECD issues transfer pricing guidance for financial transactions – OECD offers draft model rules on platform operators for ‘sharing’ and ‘gig’ economy – OECD releases eight batch of peer review reports on BEPS Action 14.