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27 June 2019

Washington Dispatch for June 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:

Treasury and IRS news

— Temporary and proposed DRD regulations reflect GILTI-centric view of international tax rules enacted under TCJA
— US government issues final and proposed GILTI and subpart F regulations, include favorable and unfavorable provisions for taxpayers
— IRS issues proposed regulations under Sections 954 and 958; important consequences for subpart F and GILTI regimes, among other provisions
— IRS releases proposed regulations on FIRPTA tax exception for qualified foreign pension funds’ gain/loss attributable to certain interests in US real property

Transfer pricing news

— Ninth Circuit panel reverses Tax Court opinion in Altera, holding stock-based compensation to be a compensable cost under IRC Section 482
— IRS LB&I withdraws CSA directive

Treaty news

— US Senate Foreign Relations Committee reports out tax protocols to treaties with Japan, Luxembourg, Spain and Switzerland

OECD news

— OECD workplan envisions global agreement on new rules for taxing multinational enterprises
— G20 Finance Ministers and Central Bank Governors welcome progress on addressing tax challenges from digitalization, reiterate commitment to final solution by 2020

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ATTACHMENT

Washington Dispatch for June 2019

Document ID: 2019-5814

 
 

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