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June 27, 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 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 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 ——————————————— Washington Dispatch for June 2019 | |||