Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

February 28, 2020

Report on recent US international tax developments 28 February 2020

The Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) this week completed its review of final regulations under Internal Revenue Code Sections 245(e) and 267A and sent them back to Treasury for final review. They joined final Section 163(j) regulations on interest limitation rules which are also back at Treasury, but which reportedly will not be released until proposed regulations under Section 163(j) have completed their ongoing OIRA review. Earlier in the month, a Treasury official was quoted as saying that final Section 901(m) regulations would be released “any day now,” but have not yet been issued.

G20 Finance Ministers met this week in Riyadh and, at the conclusion, issued a communique endorsing the Base Erosion and Profit Shifting (BEPS) 2.0 “Outline of the Architecture of a Unified Approach on Pillar One” as the basis for negotiations and welcoming progress on Pillar Two. The G20 also underscored the importance of reaching agreement on the key policy features of a digital solution by July 2020 and their commitment to reach consensus on a BEPS 2.0 final report by the end of 2020.


1. All “Section” references are to the Internal Revenue Code of 1986, and the regulations promulgated thereunder.

For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP, International Tax and Transaction Services, Washington, DC



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.


Copyright © 2024, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more