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November 4, 2020
2020-2625

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

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Washington Dispatch for October 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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