ITS Washington Dispatch, April 2016

Uncertainty regarding House international tax reform draft – Comprehensive tax reform blueprint expected by end of June – New Section 385 regulations would treat related-party corporate interests as stock, not debt -- Treasury releases new anti-corporate inversion regulations modifying application of Section 7874, limiting post-inversion tax benefits – US moving toward optional CbC reporting for 2016 – IRS issues proposed regulations under Section 305(c) deemed distributions and related withholding – Future proposed regulations will treat foreign-owned single-member LLCs as corporations for Section 6038A reporting purposes – IRS Associate Chief Counsel (International) lists top guidance priorities.