07 October 2020 EY Podcast: monthly ITS Washington Dispatch (September 2020) EY’s monthly Washington Dispatch podcast summarizes recent developments in US international taxation. Highlights of this month's edition include: - Final BEAT regulations adopt proposed BEAT guidance with some changes
- New final and newly proposed foreign tax credit regulations released
- Treasury issues final sourcing regulations on sales of personal property (including inventory)
- IRS releases final and proposed regulations re repeal of Section 958(b)(4)
- IRS issues final regs on characterization of foreign persons’ gain or loss from sale / exchange of interests in partnerships engaged in US trade or business
- Final Section 163(j) regulations generally applicable tax years on / after 13 November 2020
- IRS delays certain Section 987 FX regulations for additional year
- Notice 2020-69 provides rules on entity treatment election for certain S corporations re GILTI in AAA inclusions
- Final BEPS 2.0 Pillar 1 and 2 blueprints to be published 12 October 2020
- OECD releases third phase of peer reviews on BEPS Action 13
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