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07 October 2019

Washington Dispatch for September 2019

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

Treaty news

  • Treasury announces entry-into-force dates for tax treaty protocols with Japan, Spain, Luxembourg and Switzerland

Treasury and IRS news

  • Proposed Section 382(h) regulations would eliminate 338 safe harbor and modify built-in gain or loss calculations
  • US government expected to deliver international TCJA guidance this fall
  • IRS reconsidering Form 1120-F nonfilers compliance campaign

OECD news

  • OECD releases outcomes of second phase of peer reviews on BEPS Action 13, announces public consultation
  • OECD holds first Tax Certainty Day and releases 2018 Mutual Agreement Procedure statistics

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ATTACHMENT

Washington Dispatch for September 2019

Document ID: 2019-6243

 
 

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