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November 5, 2019
2019-6354

Washington Dispatch for October 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:

Digital taxation

  • OECD takes next step on BEPS 2.0 – Pillar One ‘unified approach’ released

Treasury and IRS news

  • Treasury issues final regulations removing Section 385 documentation requirements, issues notice of proposed rulemaking for treating some interests as debt
  • IRS announces taxpayers can still rely on expired temporary Section 385 recharacterization rules
  • IRS issues proposed regulations and Rev. Proc. 2019-40 on repeal of Section 958(b)(4)
  • IRS proposed rules address tax consequences of elimination of LIBOR, other interbank offered rates
  • New US cryptocurrency tax guidance addresses some open questions, leaves others unanswered
  • IRS Chief Counsel Advice concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete

OECD news

  • OECD releases sixth batch of peer review reports on Action 14

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ATTACHMENT

Washington Dispatch for October 2019

 
 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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