ITS Washington Dispatch, December 2016

Congress, incoming Trump Administration prepare for tax reform * Temporary and proposed regulations on covered asset acquisitions issued under Section 901(m) * Final and temporary US FX regulations issued * Final regulations retroactively eliminate Section 367(d)'s exception for foreign goodwill and going concern value * IRS releases extensive FATCA-related guidance * IRS issues final PFIC regulations * IRS finalizes regulations requiring reporting by foreign-owned US disregarded entities * IRS Notice 2016-73 announces amendments to Section 367 regulations applying to certain cross-border triangular reorganizations and inbound nonrecognition transactions * IRS issues Section 871(m) transition rules in Notice 2016-72 * IRS Notice 2017-07 modifies effective date for deferral events and outbound loss events * US, India reached agreement in first bilateral APA.