06 June 2019 Washington Dispatch for May 2019 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: — Final Section 956 regulations generally follow proposed regulations, but with two major modifications — IRS finalizes certain temporary FX regulations addressing recognition and deferral of Section 987 gain or loss — Proposed regulations under Section 1446(f) would clarify scope of withholding on transfers of partnership interests — IRS Chief Counsel legal memo addresses IP transfer to US partnership — EC comments on US FDII proposed regulations — US reiterates opposition to unilateral digital proposals, EU consensus proves elusive ——————————————— ATTACHMENT Washington Dispatch for May 2019 Document ID: 2019-1046 |