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06 November 2020

EY Podcast: monthly ITS Washington Dispatch (October 2020)

EY’s monthly Washington Dispatch podcast summarizes recent developments in US international taxation. Highlights of this month's edition include:

  • OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments
  • UN releases new proposed treaty article on digital taxes
  • Final rules under Section 1446(f) address W/H on transfers of partnership interests
  • IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership
  • IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange
  • IRS ‘practice unit’ offers exam guidance on inclusion of stock-based compensation in CSAs
  • IRS to limit use of ‘telescoping’ in APA and MAP cases
  • IRS will consider amending existing APAs to reflect COVID-19 economic conditions

Register for this monthly podcast on iTunes here.

Document ID: 2020-6435

 
 

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