Ernst & Young Its Washington Dispatch

US Treasury and IRS issue final and temporary Section 385 debt/equity regulations – What taxpayers should do now that final Section 385 regulations are released – IRS officials say cross-border intangible guidance, Section 871(m) package coming soon – US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation – US to exchange summaries of unilateral APAs in accordance with BEPS Action 5 – OECD holds consultation on BEPS profit attribution to PEs, revised guidance on profit splits – OECD released BEPS Action 14, "More Effective Dispute Resolution Mechanisms," peer review documents.