ITS Washington Dispatch, February 2018

US government moving forward with TCJA international guidance, two more transition notices expected -- IRS guidance under new Section 965 prevents certain foreign corporations from making accounting period changes -- New guidelines issued for delinquent Forms 1120-F and waiver requests -- Treasury may delay Section 987 branch currency regulations until 2020 -- IRS updates Priority Guidance Plan with some TCJA international provisions -- IRS assumes major role in OECD’s International Compliance Assurance Program -- IRS announces increase in user fees for unilateral and bilateral APAs -- OECD releases additional CbCR guidance, country approaches to CbC reporting