The latest edition of Tax News: Investing in the USA is attached below. Prepared by Ernst & Young's International Tax Services group, this communication summarizes recent international tax developments in the United States pertinent to multinational companies based outside the United States. Highlights of this edition include:

Legislation

— Congress, incoming Trump Administration prepare for tax reform

Treasury/IRS news

— Treasury and IRS release final and temporary debt/equity regulations under Section 385
— IRS finalizes regulations requiring reporting by foreign-owned US disregarded entities
— IRS issues Section 871(m) transition rules in Notice 2016-72
— US IRS to exchange summaries of unilateral APAs under BEPS
— US, India reach first bilateral advance pricing agreement
— IRS releases extensive FATCA-related guidance

OECD BEPS news

— OECD releases multilateral instrument to implement treaty related BEPS measures on hybrid mismatch arrangements, treaty abuse, permanent establishment status and dispute resolution
— OECD updates guidance on Country-by-Country Reporting and launches new site on country-specific implementation
— OECD releases schedule of Action 14 peer reviews
— OECD releases BEPS Action 14 on More Effective Dispute Resolution Mechanisms, Peer Review
— OECD held public consultation on attribution of profits to PEs and profit splits

Treaty rates

— Treaty withholding tax rates

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ATTACHMENT

Investing in the USA for December 2016