Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: Acting IRS Commissioner talks at May 2018 ABA Section of Taxation meeting about guidance projects implementing the TCJA – Treasury and IRS officials also address several tax reform related issues at the Meeting – IRS official reports IRS considering whether potential regulations under Section 267A should prevent the denial of deductions when a hybrid instrument or entity is not the cause of preferential treatment of relevant income – US District Court dismisses taxpayer’s suit against IRS in transfer pricing dispute.