08 May 2020 EY Podcast: monthly ITS Washington Dispatch (April 2020) EY’s monthly Washington Dispatch podcast summarizes recent developments in US international taxation. Highlights of this month's edition include: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financingIRS regulations include new anti-abuse rule targeting certain ‘GILTI gap period’ transactionsTaxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusionsIRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES ActIRS provides relief for potential tax consequences caused by COVID-19 travel restrictionsIRS withdraws 2004 Notice on ‘Midco’ transactionsIRS releases FAQs on transfer pricing documentation best practicesIRS issues annual APA report for 2019IRS updates FATCA FAQsOECD BEPS 2.0 project to continue on current timelinesOECD issues guidance on impact of the COVID-19 crisis on treaty-related issuesOECD releases second batch of Stage 2 peer review reports on dispute resolution Register for this monthly podcast on iTunes here. Document ID: 2020-5706 |