Miscellaneous
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership interests – IRS concludes Section 704(c) anti-abuse rule triggered in asset contribution to foreign partnership – IRS confirms some modifications to debt instruments, other contracts to reflect LIBOR discontinuation will not result in deemed taxable exchange – IRS ‘practice unit’ offers exam guidance on inclusion of stock-based compensation in CSAs – IRS to limit use of ‘telescoping’ in APA and MAP cases – IRS will consider amending existing APAs to reflect COVID-19 economic conditions.