Ey Cross-border Taxation Alerts

A review of this week's major US international tax-related news. In this edition:  US House Speaker promises “Day One” focus on corporate tax policy with Republican election sweep – IRS soon to release final Section 367(d) regs on IP repatriation – IRS final Section 987 FX regs to reserve on partnership issues – IRS guidance on BEPS Pillar One Amount B coming before year end – IRS official clarifies ‘disregarded payment loss’ rules effective date in recent DCL regs – IRS soon to release guidance on MAP and APA program – IRS assembling CAP transfer pricing team – OECD issues seventh annual BEPS Action 13 CbCR peer review report.