EY ITS Washington Dispatch, April 2020

Ernst & Young ITTS Washington Dispatch

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new anti-abuse rule targeting certain ‘GILTI gap period’ transactions – Taxpayers need to consider international tax implications of making certain NOL elections under Rev. Proc. 2020-24 – IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions – IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act – IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions – IRS withdraws 2004 Notice on ‘Midco’ transactions – IRS releases FAQs on transfer pricing documentation best practices – IRS issues annual APA report for 2019 – IRS updates FATCA FAQs – OECD BEPS 2.0 project to continue on current timelines – OECD issues guidance on impact of the COVID-19 crisis on treaty-related issues – OECD releases second batch of Stage 2 peer review reports on dispute resolution.