Ernst & Young Its Washington Dispatch

Congress begins August recess; concern over corporate inversions -- IRS clarifies foreign tax credit guidance under Section 901(m)to prevent abuse -- IRS updates procedures for withholding foreign partnerships and withholding foreign trusts -- IRS issues PLR on treatment of certain foreign stock under Section 7874 -- IRS rules consent fee paid on contingent payment debt instrument may result in a taxable exchange -- IRS finalizes regulations applying straddle rules to certain debt instruments -- IRS CCA addresses when late-received documentation can support portfolio interest exemption -- OECD releases report on impact of BEPS in low income countries -- OECD seeks input on collecting and analyzing data on BEPS.