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