Ernst & Young ITTS Washington Dispatch

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden lays out $2 trillion + infrastructure plan to be paid for with tax increases – Senate Finance Committee holds international tax hearing – Congressional Democrats introduce international tax legislation – President Biden signs $1.9 trillion American Rescue Plan Act of 2021 – US, Japan reach agreement on tax treaty arbitration process – IRS opens initiative on virtual currency – IRS APMA program director discusses taxpayers' treatment of COVID-related costs – IRS APMA Program releases annual APA update – OECD official floats BEPS 2.0 Pillar Two simplification – OECD publishes jurisdictions currently participating in International Compliance Assurance Programme.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress poised to enact $1.9t COVID relief bill with repeal of worldwide interest expense allocation – Treasury to consider reviving expired transfer pricing aggregation regulations – IRS continues APA/MAP case closures despite COVID restrictions – OECD FTA releases new handbook for ICAP – OECD holds public consultation on review of BEPS Action 14 minimum standard on dispute resolution – OECD releases 10th batch of peer review reports on BEPS Action 14.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary says no new taxes for now, commits to OECD BEPS discussions – New final regulations address application of Section 163(j) limitation to CFCs and partnerships, reserve on certain provisions – IRS allows remote signing / submission of authorization Forms 2848 and 8821 – IRS official says guidance on worldwide interest expense allocation a top priority, proposed FTC regs in 2021 – USTR finds DSTs adopted by six nations discriminatory; suspends DST-related punitive tariff actions on French goods – OECD IF political leaders promote global consensus following OECD public consultation on Pillar One / Two Blueprints – OECD Secretariat issues updated guidance on tax treaties re impact of COVID-19 pandemic.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax treaties as TCJA guidance nears completion – Treasury's FinCEN further extends certain FBAR signature authority reporting over foreign financial accounts – IRS will continue ICAP joint risk assessment initiative – US transfer pricing enforcement remains priority while TCJA provisions may negate adjustments – IRS APMA seeing more queries on transfer pricing consequences of coronavirus pandemic – BEPS 2.0 Pillar One and Two comment period closes; public consultation set for 14-15 January 2021 – OECD issues guidance on transfer pricing implications of COVID-19, hard-to-value intangibles – OECD releases fourth peer review report on BEPS Action 5 on Exchange of Information of Tax Rulings – OECD's FTA hosts virtual meeting of tax administration leaders.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Major policy changes expected following US November election – Treasury and IRS finalize regulations to reduce double taxation caused by anti-abuse rules on GILTI gap period – IRS officials provide international regulatory update – US, Mexico renew competent authority agreement on unilateral APAs for maquiladoras – IRS updates list of jurisdictions for automatic exchange of CbC reports – IRS reviewing stock-based compensation in cost-sharing context – OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 in mid-January 2021 – OECD releases Consultation Document on 2020 review of BEPS Action 14 – OECD releases 2019 mutual agreement procedure statistics, 2019 mutual agreement procedure awards – OECD releases report on taxing virtual currencies.

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 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS 'practice unit' offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of 'telescoping' in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.

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 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS 'practice unit' offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of 'telescoping' in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.

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 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS 'practice unit' offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of 'telescoping' in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.

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 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS 'practice unit' offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of 'telescoping' in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Final BEAT regulations adopt proposed BEAT guidance with some changes − New final and newly proposed foreign tax credit regulations released − Treasury issues final sourcing regulations on sales of personal property (including inventory) − IRS releases final and proposed regulations re repeal of Section 958(b)(4) − IRS issues final regs on characterization of foreign persons' gain or loss from sale / exchange of interests in partnerships engaged in US trade or business − Final Section 163(j) regulations generally applicable tax years on / after 13 November 2020 − IRS delays certain Section 987 FX regulations for additional year − Notice 2020-69 provides rules on entity treatment election for certain S corporations re GILTI in AAA inclusions − Final BEPS 2.0 Pillar 1 and 2 blueprints to be published 12 October 2020 − OECD releases third phase of peer reviews on BEPS Action 13.