ITS Washington Dispatch, February 2015 - a podcast by Ernst & Young

Obama Administration’s FY 2016 Budget proposes major overhaul of US international tax system – IRS finalizes regulations under Section 909 foreign tax credit splitting events – IRS Chief Counsel memo addresses application of tax rate disparity test for foreign sales branches – IRS concludes US shareholder must increase E&P in year of Section 951(a)(1) inclusion – IRS releases competent authority agreement with Kazakhstan on treaty benefits for fiscally transparent entities – OECD addresses BEPS Actions 5, 13, and 15 – OECD holds public consultation on BEPS Action 4 on interest deductions and other financial payments.

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