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: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – Treasury and IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules during GILTI gap period – US, Swiss competent authorities reach agreement on treaty arbitration process – UN Tax Committee issues proposal for taxing digital services income.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII and GILTI deduction – IRS releases new draft partnership Schedules K-2 and K-3 for international tax reporting – US announces action against France's DST – G20 Finance Ministers / Central Bank Governors reiterate commitment to BEPS 2.0 pillars – OECD releases new corporate tax data including CbCR statistics – OECD issues model rules for data reporting by platform operators for sellers in sharing / gig economy.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for 'pause' in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I official offers insights to TCJA compliance campaign – IRS seeks 2020-2021 Priority Guidance Plan recommendations – OECD releases toolkit on taxation of offshore indirect transfers of assets – OECD circulates COVID-19 transfer pricing survey to BIAC members.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress considers further action to address coronavirus pandemic – IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect – Treasury and IRS announce references to NAFTA in US tax treaties should be interpreted as references to USMCA – IRS offers limited relief for filing Forms 8858 or 8865 – IRS announces modifications for filing APA and MAP requests, addresses pending and executed APAs – New refocusing on BEPS, OECD official says – OECD holds public consultation on 2020 review of CbCR – OECD hosts webcast offering update on tax work during COVID-19 crisis; July IF meeting delayed to October 2020.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV'ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new anti-abuse rule targeting certain 'GILTI gap period' transactions – Taxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24 – IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions – IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act – IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions – IRS withdraws 2004 Notice on 'Midco' transactions – IRS releases FAQs on transfer pricing documentation best practices – IRS issues annual APA report for 2019 – IRS updates FATCA FAQs – OECD BEPS 2.0 project to continue on current timelines – OECD issues guidance on impact of the COVID-19 crisis on treaty-related issues – OECD releases second batch of Stage 2 peer review reports on dispute resolution.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US CARES Act stimulus package to address COVID-19 has international tax implications – IRS expands 15 April tax relief and issues FAQs on extension of filing and payment deadlines, FATCA reporting – IRS issues final Section 901(m) regulations – TIGTA finds major FIRPTA withholding discrepancies – Alignment of transfer pricing regulations to TCJA provisions in relation to IP definition not expected before 2021 – OECD plans to continue BEPS 2.0 project virtually – OECD releases second annual peer review report on BEPS Action 6, prevention of treaty abuse – OECD releases CbCR comments.

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.

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.

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.

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.