EY ITS Washington Dispatch, October 2019

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concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete – OECD releases sixth batch of peer review reports on BEPS Action 14.