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 debtIRS announces taxpayers can still rely on expired temporary Section 385 recharacterization rulesIRS 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 ratesNew US cryptocurrency tax guidance addresses some open questions, leaves others unansweredIRS CCA concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsoleteOECD releases sixth batch of peer review reports on BEPS Action 14 Register for this monthly podcast on iTunes here. Document ID: 2019-6384 |