Ernst & Young Its Washington Dispatch

US international tax reform, repatriation considered to pay for Highway Trust Fund -- Congressional tax leaders express BEPS project concerns -- Bill introduced to close PFIC ‘loophole’ -- IRS issues final Section 7874 regulations; retains bright-line rule of SBAT -- IRS reiterates that principles of Notice 2012-39 retroactively apply to outbound F reorgs with CFC shareholder -- OECD releases discussion draft on hard-to-value intangibles under BEPS Action 8 -- OECD issues implementation package for CbC reporting under BEPS Action 13 – Seven more countries agree to Common Reporting Standard.