EY Cross-Border Taxation Spotlight for Week ending 18 December 2020

A review of the week's major US international tax-related news. In this edition: Treasury sends final Section 163(j) interest expense limitation regulations to OMB for review – Treasury notes progress on new tax treaty with Croatia; resumption of US Senate approvals of bilateral tax treaties expected – IRS will continue to prioritize transfer pricing enforcement in examinations, even if adjustment negated by TCJA provisions – Treasury’s FINCEN further extends FBAR filing deadline – OECD BEPS 2.0 Pillar 1 and Pillar 2 comment period ends; BIAC calls for limited BEPS agreement by June 2021 – OECD publishes jurisdiction-specific information on implementation of hard-to-value intangibles approach.