EY ITS Washington Dispatch, October 2019

11/06/19 • 20 min

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar One ‘unified approach’ – Treasury issues final regulations removing Section 385 documentation requirements, notice of proposed rulemaking for treating some interests as debt – IRS announces taxpayers can still rely on expired temporary Section 385 recharacterization rules – IRS issues proposed regulations and Rev. Proc. 2019-40 on repeal of Section 958(b)(4) – IRS proposed rules address tax consequences of elimination of LIBOR, other interbank offered rates – New US cryptocurrency tax guidance addresses some open questions, leaves others unanswered -- IRS CCA concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete – OECD releases sixth batch of peer review reports on BEPS Action 14.

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EY ITS Washington Dispatch, September 2019

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury announces entry-into-force for protocols with Japan, Spain, Luxembourg, and Switzerland – IRS issues proposed Section 382(h) regulations on built-in gains and losses – International TJCA guidance expected in fall – IRS reconsidering Form 1120-F nonfiler compliance campaign – OECD releases second phase BEPS Action 13 peer review – OECD holds first Tax Certainty Day, releases 2018 MAP statistics.

Next Episode

EY ITS Washington Dispatch, November 2019

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD issues consultation document on technical design of Pillar Two – IRS issues final regulations on ownership attribution rules for CFC purposes – IRS announces Section 965 transition tax compliance campaign – Treasury officials offer TJCA international guidance timeline – Ninth Circuit denies en banc rehearing in Altera – US government aware transfer pricing may be used to reduce TJCA tax liability – Cyprus announces coming bilateral CbCR Competent Authority Agreement with US – OECD holds public consultation on Pillar One – OECD releases ADIMA database with global MNE profiles – OECD releases more guidance on spontaneous exchange of information by no or nominal tax jurisdictions – OECD releases additional guidance on CbC Reporting, summary of common MNE errors.