January 8, 2021 2021-0050 Washington Dispatch for December 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: Legislation - US Congress passes coronavirus stimulus and omnibus spending package that includes extension of CFC look-through
IRS news - IRS issues final and proposed PFIC regulations that provide mix of favorable and unfavorable provisions
- Final and proposed regulations on passive foreign investment companies have both favorable and unfavorable implications for insurance companies
- Treasury to focus on other international projects, tax treaties as TCJA guidance nears completion
- Treasury’s FinCEN further extends certain signature authority reporting (FBAR, Form 114) over foreign financial accounts
Transfer Pricing News - Transfer pricing enforcement remains priority even while TCJA provisions may negate adjustments
- IRS APMA seeing more queries on transfer pricing consequences of coronavirus pandemic
OECD Developments - OECD issues guidance on transfer pricing implications of COVID-19, hard- to-value intangibles
- OECD releases fourth peer review report on BEPS Action 5 on the Exchange of Information of Tax Rulings
- OECD’s FTA hosts virtual meeting of tax administration leaders
——————————————— ATTACHMENT Washington Dispatch for December 2020 
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