The controversial final Section 385 regulations are still being debated, with Treasury focusing on earnings stripping issues, although seemingly has heard valuable comments as to its detrimental effect on physical or notional cash pooling. Every MNE should have read the proposed Reg’s and educated their treasury and finance functions accordingly, which should be an immediate priority due to its expansive potential effect on treasury, legal and tax structures going forward.
The US House is set to release its tax blueprint next week, which may become more important if a Republican president is elected with potential reforms again in play.
EY’s Global Tax Alert discusses these topics and some BEPS updates.
Strategizing Multinational Tax Risks 
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