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October 2, 2020
2020-2391

Washington Dispatch for September 2020

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

  • Final BEAT regulations adopt proposed BEAT guidance with some changes
  • Treasury releases final and newly proposed foreign tax credit regulations
  • Treasury issues final sourcing regulations on sales of personal property (including inventory)
  • IRS releases final and proposed regulations related to the repeal of Section 958(b)(4)
  • IRS issues final regulations on characterization of foreign persons’ gain or loss from sale / exchange of interests in partnerships engaged in a US trade or business
  • IRS delays certain Section 987 foreign currency regulations for additional year
  • Notice 2020-69 provides rules on entity treatment election for certain S corporations for purposes of GILTI in AAA inclusions

OECD developments

  • Final BEPS 2.0 Pillar 1 and 2 blueprints will be published on 12 October
  • OECD releases outcomes of third phase of peer reviews on BEPS Action 13

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Washington Dispatch for September 2020

 

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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