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November 4, 2020

Washington Dispatch for October 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:

Top story

  • OECD releases Pillar 1 and Pillar 2 blueprints, invites public comments

IRS news

  • Final regulations under Section 1446(f) set forth rules on withholding on transfers of partnership interests
  • IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership
  • IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in a deemed taxable exchange

Transfer pricing news

  • IRS ‘practice unit’ sets forth examination guidance on inclusion of stock based compensation in cost sharing arrangements
  • IRS announces plans to limit use of ‘telescoping’ in APA and MAP cases
  • IRS will consider amending existing APAs to reflect COVID-19 economic conditions

OECD Developments

  • OECD issues third batch of Stage review reports on dispute resolution
  • OECD to release COVID-19-related transfer pricing guidance


Washington Dispatch for October 2020