A review of the week's major US international tax-related news. In this edition: US Treasury releases final FDII/GILTI regulations – OMB completes review of final regulations on GILTI high-tax exclusion, proposed rules under Section 954(b)(4) high-taxed subpart F income and Section 964 re: E&P of a foreign corporation – IRS seeing more multilateral APA requests – OECD releases model rules for reporting by platform operators regarding sellers in the sharing and gig economy.