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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

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Washington Dispatch for December 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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