06 June 2019

Washington Dispatch for May 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:

IRS news

— Final Section 956 regulations generally follow proposed regulations, but with two major modifications
— IRS finalizes certain temporary FX regulations addressing recognition and deferral of Section 987 gain or loss
— Proposed regulations under Section 1446(f) would clarify scope of withholding on transfers of partnership interests
— IRS Chief Counsel legal memo addresses IP transfer to US partnership
— EC comments on US FDII proposed regulations

Digital taxation

— US reiterates opposition to unilateral digital proposals, EU consensus proves elusive

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ATTACHMENT

Washington Dispatch for May 2019

Document ID: 2019-5727