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08 January 2021

Washington Dispatch for December 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:

Legislation

  • US Congress passes coronavirus stimulus and omnibus spending package that includes extension of CFC look-through

IRS news

  • IRS issues final and proposed PFIC regulations that provide mix of favorable and unfavorable provisions
  • Final and proposed regulations on passive foreign investment companies have both favorable and unfavorable implications for insurance companies
  • Treasury to focus on other international projects, tax treaties as TCJA guidance nears completion
  • Treasury’s FinCEN further extends certain signature authority reporting (FBAR, Form 114) over foreign financial accounts

Transfer pricing news

  • Transfer pricing enforcement remains priority even while TCJA provisions may negate adjustments
  • IRS APMA seeing more queries on transfer pricing consequences of coronavirus pandemic

OECD developments 

  • OECD issues guidance on transfer pricing implications of COVID-19, hard-to-value intangibles
  • OECD releases fourth peer review report on BEPS Action 5 on the Exchange of Information of Tax Rulings 
  • OECD’s FTA hosts virtual meeting of tax administration leaders 

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ATTACHMENT

Washington Dispatch for December 2020

Document ID: 2021-5020

 
 

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