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June 3, 2020

Washington Dispatch for May 2020

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:


  • Congress considers further action to address coronavirus pandemic 

IRS news

  • IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect for now
  • Treasury and IRS announce references to NAFTA in US tax treaties should be interpreted as references to the USMCA
  • IRS offers limited relief for filing Forms 8858 or 8865

Transfer pricing news

  • IRS announces modifications for filing APA and MAP requests, addresses pending and executed APAs 

OECD news

  • New refocusing on BEPS, OECD official says 
  • OECD holds public consultation on 2020 review of CbCR 
  • OECD hosts webcast offering update on tax work during COVID-19 crisis; July IF meeting delayed to October 2020


Washington Dispatch for May 2020


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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