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
——————————————— ATTACHMENT Washington Dispatch for October 2020 
|