globaltaxnews.ey.comSign up for tax alert emailsPrintDownload

04 November 2020

Washington Dispatch for October 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:

Top story

  • OECD releases Pillar 1 and Pillar 2 blueprints, invites public comments 

IRS news

  • Final regulations under Section 1446(f) set forth rules on withholding on transfers of partnership interests 
  • IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership 
  • IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in a deemed taxable exchange

Transfer pricing news

  • IRS ‘practice unit’ sets forth examination guidance on inclusion of stock based compensation in cost sharing arrangements
  • IRS announces plans to limit use of ‘telescoping’ in APA and MAP cases
  • IRS will consider amending existing APAs to reflect COVID-19 economic conditions

OECD developments 

  • OECD issues third batch of Stage 2 peer review reports on dispute resolution
  • OECD to release COVID-19-related transfer pricing guidance

———————————————
ATTACHMENT

Washington Dispatch for October 2020

Document ID: 2020-6431

 
 

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 ey.com. Please refer to the privacy notice/policy on these sites for more information.


Yes, I accept         Find out more