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:

Digital Taxation

— OECD takes next step on BEPS 2.0 – Pillar One ‘unified approach’ released

Treasury and IRS news

— Treasury issues final regulations removing Section 385 documentation requirements, issues notice of proposed rulemaking for treating some interests as debt

— IRS announces taxpayers can still rely on expired temporary Section 385 recharacterization rules

— IRS issues proposed regulations and Rev. Proc. 2019-40 on repeal of Section 958(b)(4)

— IRS proposed rules address tax consequences of elimination of LIBOR, other interbank offered rates

— New US cryptocurrency tax guidance addresses some open questions, leaves others unanswered

— IRS Chief Counsel Advice concludes 952(c) election to include otherwise excludible insurance income in subpart F income of CFCs’ US shareholders is obsolete

OECD News

— OECD releases sixth batch of peer review reports on Action 14

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Washington Dispatch for October 2019