EY ITS Washington Dispatch, September 2019

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury announces entry-into-force for protocols with Japan, Spain, Luxembourg, and Switzerland – IRS issues proposed Section 382(h) regulations on built-in gains and losses – International TJCA guidance expected in fall – IRS reconsidering Form 1120-F nonfiler compliance campaign – OECD releases second phase BEPS Action 13 peer review – OECD holds first Tax Certainty Day, releases 2018 MAP statistics.