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07 October 2019

Washington Dispatch for September 2019

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young'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

— Treasury announces entry-into- force dates for tax treaty protocols with Japan, Spain, Luxembourg and Switzerland

Treasury and IRS news

—Proposed Section 382(h) regulations would eliminate 338 safe harbor and modify built-in gain or loss calculations

— US government expected to deliver international TCJA guidance this fall

— IRS reconsidering Form 1120-F nonfilers compliance campaign

OECD News

— OECD releases outcomes of second phase of peer reviews on BEPS Action 13, announces public consultation

— OECD holds first Tax Certainty Day and releases 2018 Mutual Agreement Procedure statistics

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ATTACHMENT

Washington Dispatch for September 2019

Document ID: 2019-1779

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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