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:

Treasury and IRS news

— US officials offer new insights in coming international guidance

— IRS final regulations on US partner contributions to partnerships with related foreign partners have few changes from prior temporary regulations

— Final FATCA and chapter 3 regulations issued

— IRS will consider certain requests for double taxation relief due to Section 965 repatriation

— IRS rules target’s capitalized transaction costs do not create a separate and distinct intangible asset

OECD news

— OECD announces renewed IF commitment for 2020 consensus on new international tax rules under BEPS 2.0

— OECD releases additional guidance on CbCR and summary of related notification requirements

— OECD releases third peer review report on Action 5 on the exchange of tax rulings

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ATTACHMENT

Washington Dispatch for January 2020