Ernst & Young Its Washington Dispatch

Congress mulls anti-inversion action -- Proposed US-Poland treaty, Spanish tax protocol move to Senate -- Top LB&I officials announce resignation -- IRS issues foreign tax credit guidance under Section 901(m) -- Final Section 861 interest expense allocation and apportionment regs issued; address corporate partners with 10% + interest and users of FMV asset method -- Final Section 1092 mixed straddle regulations limit ability to trigger built-in gains and losses -- IRS issues instructions for Form W-8BEN-E, other forms -- IRS can notify w/holding agent of foreign taxpayer's incorrect claim of withholding tax exemption -- OECD publishes Standard of Automatic Exchange of Financial Information in Tax Matters -- OECD Council adopts 2014 update to Model Tax Treaty