Ernst & Young Its Washington Dispatch

US midterm elections change tax landscape; extenders activity dominates tax agenda in lame duck -- IRS issues regulations on deficient GRAs; withdraws Directive for remedying incomplete GRAs -- IRS releases limited supplemental guidance on codified economic substance doctrine -- IRS rules back-to-back loans structured to avoid Section 956 -- OECD releases discussion draft on low value-adding intra-group services, public discussion draft on follow-up work on treaty abuse under BEPS Action 6.