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06 November 2019

EY Podcast: monthly ITS Washington Dispatch (October 2019)

 EY’s monthly Washington Dispatch podcast summarizes recent developments in US international taxation. Highlights of this month's edition include:

OECD releases BEPS 2.0 Pillar One ‘unified approach’

  • Treasury issues final regulations removing Section 385 documentation requirements, 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 CCA concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete
  • OECD releases sixth batch of peer review reports on BEPS Action 14

    • Register for this monthly podcast on iTunes here.

    Document ID: 2019-6384

     
     

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