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October 2, 2020

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


Washington Dispatch for September 2020