Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US Treasury issues final and proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules – New anti-abuse rule targets certain "GILTI gap period" transactions – IRS issues CARES Act guidance on NOLs – IRS significantly broadens COVID-19 tax return filing and payment relief – IRS withdraws Notice 2004-2 that identified so-called ‘Midco’ listed transactions – IRS issues 2019 APA annual report.