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 issues consultation document on technical design aspects of Pillar Two

Treasury and IRS news

- IRS issues final regulations on ownership attribution rules for CFC purposes

- IRS announces campaign to audit Section 965 transition tax compliance

- Treasury officials offer TCJA international guidance timeline

Transfer Pricing news

- Ninth Circuit denies en banc rehearing in Altera

- US Tax Court rules no Section 6662 penalties after IRS abused discretion in canceling APAs

- US government aware transfer pricing may be used to reduce TCJA tax liability

- Cyprus announces coming bilateral CbCR Competent Authority Agreement with United States

OECD Developments

- OECD holds public consultation on Pillar One of BEPS 2.0

- OECD releases database to provide insights on global profiles of individual multinational enterprises

- OECD releases additional guidance on spontaneous exchange of information by no or only nominal tax jurisdictions

- OECD releases additional guidance on CbC Reporting, summary of common errors made by MNE groups in preparing reports

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Washington Dispatch for November 2019