ITS Washington Dispatch, July 2017

House border adjustability will not be part of US tax reform -- Nomination of next Treasury Assistant Secretary for Tax Policy advances in Senate -- IRS delays Section 385 documentation requirements by one year-- US signs more CbC competent authority arrangements -- New IRS CbC reporting site offers latest forms and guidance – Government issues corrections to reporting / withholding regs under FATCA, Chapters 3 and 61-- Deadline for MNCs to request suspension of MAP-related deadline under Mexico-US tax treaty -- Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments -- Tax Court holds US parent's CFCs held US Property under Section 956 from intercompany transactions -- Tax Court rules IRS abused discretion in cancelling APAs -- OECD releases update of Guidance on the Implementation of Country-by-Country Reporting -- OECD releases draft 2017 update to the OECD Model Tax Convention -- OECD releases 2017 Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations -- OECD updates G20 Leaders on tax progress -- OECD, UN, IMF and World Bank issue toolkit to address difficulties in accessing comparable data for TP analysis.