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December 6, 2019

Washington Dispatch for November 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 issues consultation document on technical design aspects of Pillar Two

Treasury and IRS news

  • IRS issues final regulations on ownership attribution rules for CFC purposes
  • IRS announces campaign to audit Section 965 transition tax compliance
  • Treasury officials offer TCJA international guidance timeline

Transfer pricing news

  • Ninth Circuit denies en banc rehearing in Altera
  • US Tax Court rules no Section 6662 penalties after IRS abused discretion in canceling APAs
  • US government aware transfer pricing may be used to reduce TCJA tax liability
  • Cyprus announces coming bilateral CbCR Competent Authority Agreement with United States

OECD news

  • OECD holds public consultation on Pillar One of BEPS 2.0
  • OECD releases database to provide insights on global profiles of individual multinational enterprises
  • OECD releases additional guidance on spontaneous exchange of information by no or only nominal tax jurisdictions
  • OECD releases additional guidance on CbC Reporting, summary of common errors made by MNE groups in preparing reports


Washington Dispatch for November 2019


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