ITS Washington Dispatch, August 2018

Ernst & Young ITTS Washington Dispatch

US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable return of capital - DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations - Ninth Circuit withdraws opinion reversing Tax Court in Altera — US Tax Court rules Section 1446 W/H tax liability is a partnership item -- Eighth Circuit vacates Tax Court opinion in Medtronic, remands to Tax Court for further consideration -- OECD releases fourth batch of peer review reports on Action 14