ITS Washington Dispatch, May 2015

US Treasury proposes revisions to US Model Tax Treaty – Senate Finance Committee tax reform working groups deadline extended – US court disallows FTC claim under US-UK treaty for withholding tax on substitute dividend payments – DC Circuit rules retrocession agreements between foreign reinsurance companies not taxable under Section 4371 – PLR distinguishes broadcasting from motion pictures under royalties article in US tax treaty – IRS reiterates position that principles of Notice 2012-39 apply retroactively to outbound F reorg with CFC shareholder – OECD holds public consultations on Action 12 and Action 3 – OECD releases revised discussion draft on preventing artificial avoidance of PE status – OECD official takes aim at multinational tech companies.