29 March 2019

Washington Dispatch for March 2019

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young's International Tax Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:

OECD developments

— OECD holds consultation on tax challenges of digitalization with aggressive 2020 timeline for consensus

Treasury and IRS news

— IRS issues proposed Section 250 regulations on calculating FDII and GILTI deduction
— Final GILTI regulations coming by summer, proposed PTI regs late summer / early fall
— IRS releases final FATCA regulations covering compliance and verification procedures
— EU comments on Section 59A BEAT provision

Transfer pricing news

— IRS APMA releases Functional Cost Diagnostic Model to be used in certain APAs
— IRS requiring transfer pricing teams to consult with APMA in certain cases
— IRS releases 2018 APA results

Puerto Rico update

— Puerto Rico’s Treasury Department issues guidance for mandatory electronic filing of CIT returns for 2018 tax year

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ATTACHMENT

Washington Dispatch for March 2019

Document ID: 2019-5429