OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments on US Section 59A BEAT regulations – IRS APMA releases Functional Cost Diagnostic Model for certain APAs – IRS requiring TP teams to consult with APMA in certain cases – IRS releases 2018 APA results – US, India sign CbC exchange agreement – OECD releases beneficial ownership toolkit