ITS Washington Dispatch, April 2016 - a podcast by Ernst & Young

from 2016-04-30T16:30:56

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Uncertainty regarding House international tax reform draft – Comprehensive tax reform blueprint expected by end of June – New Section 385 regulations would treat related-party corporate interests as stock, not debt -- Treasury releases new anti-corporate inversion regulations modifying application of Section 7874, limiting post-inversion tax benefits – US moving toward optional CbC reporting for 2016 – IRS issues proposed regulations under Section 305(c) deemed distributions and related withholding – Future proposed regulations will treat foreign-owned single-member LLCs as corporations for Section 6038A reporting purposes – IRS Associate Chief Counsel (International) lists top guidance priorities.

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