EY ITS Washington Dispatch, November 2019

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD issues consultation document on technical design of Pillar Two – IRS issues final regulations on ownership attribution rules for CFC purposes – IRS announces Section 965 transition tax compliance campaign – Treasury officials offer TJCA international guidance timeline – Ninth Circuit denies en banc rehearing in Altera – US government aware transfer pricing may be used to reduce TJCA tax liability – Cyprus announces coming bilateral CbCR Competent Authority Agreement with US – OECD holds public consultation on Pillar One – OECD releases ADIMA database with global MNE profiles – OECD releases more guidance on spontaneous exchange of information by no or nominal tax jurisdictions – OECD releases additional guidance on CbC Reporting, summary of common MNE errors.