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November 5, 2019

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concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete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


Washington Dispatch for October 2019


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