05 December 2018

Washington Dispatch for November 2018

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young's International Tax Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:

Legislation

— Congress returns for lame-duck session; year-end tax bill taking shape

Treasury and IRS news

— IRS releases proposed regulations and related guidance on computing interest expense limitation under Section 163(j
— IRS issues proposed foreign tax credit regulations
— IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j)
— Taxpayers told to expect more informal IRS guidance, including on cryptocurrencies
— IRS adds four new LB&I international compliance campaigns

Transfer pricing news

— US, Japan sign Country-by-Country Reporting exchange of information arrangement

Treaty news

— Netherlands to repeal Decree re US-Netherlands tax treaty regarding hybrid entities

OECD developments

— OECD releases guidance for development of synthesized texts and note clarifying entry into effect of BEPS Multilateral Convention
— OECD releases updated results on scrutiny of preferential tax regimes and substantial activity requirements for no or only nominal tax jurisdictions
— OECD moves on BEPS Action 14 minimum standard peer review for another group of jurisdictions

———————————————
ATTACHMENT

Washington Dispatch for November 2018

Document ID: 2018-2404