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January 9, 2020

Washington Dispatch for December 2019

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young LLP'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

  • US releases trade investigation findings regarding France’s Digital Services Tax; proposes imposition of tariffs

Treasury and IRS news

  • US issues final and proposed BEAT regulations, with some relief for taxpayers
  • IRS final and proposed regulations provide additional guidance for determining allowable foreign tax credits
  • IRS issues final withholding and reporting regulations
  • IRS issues final Section 871(m) regulations on dividend equivalent payments on derivatives referencing US equities, extends transition relief
  • IRS issues proposed regulations on sourcing income from sales of certain personal property
  • IRS further delays certain Section 987 foreign currency regulations
  • Treasury grants another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts

OECD news

  • Officials discuss OECD BEPS 2.0 Project
  • OECD hosts public consultation on global anti-base erosion (GloBE) proposal under Pillar Two of BEPS 2.0 project
  • OECD releases additional CbC guidance
  • OECD releases seventh batch of peer review reports on BEPS Action 14


Washington Dispatch for December 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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