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

• US releases trade investigation findings regarding France’s Digital Services Tax; proposes imposition of tariffs

Treasury and IRS news

• US issues final and proposed BEAT regulations, with some relief for taxpayers
• IRS final and proposed regulations provide additional guidance for determining allowable foreign tax credits
• IRS issues final withholding and reporting regulations
• IRS issues final Section 871(m) regulations on dividend equivalent payments on derivatives referencing US equities, extends transition relief
• IRS issues proposed regulations on sourcing income from sales of certain personal property
• IRS further delays certain Section 987 foreign currency regulations
• Treasury grants another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts

OECD news

• Officials discuss OECD BEPS 2.0 Project
• OECD hosts public consultation on global anti-base erosion (GloBE) proposal under Pillar Two of BEPS 2.0 project
• OECD releases additional CbC guidance
• OECD releases seventh batch of peer review reports on BEPS Action 14

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ATTACHMENT

Washington Dispatch for December 2019