Daily Tax Update - June 15, 2015: OECD Releases Public Comments on BEPS Draft Regarding the Artificial Avoidance of Permanent Establishment Status

OECD Releases Public Comments on BEPS Draft Regarding the Artificial Avoidance of Permanent Establishment Status:  Today, the OECD released public comments on its revised discussion draft on Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) of the Base Erosion and Profit Shifting (BEPS) Action Plan.  The comments, totaling more than 300 pages, address a number of issues, including the use of commissionaire arrangements and the specific activity exemptions.

Miscellaneous Guidance: 
Revenue Procedure 2015-37 amplifies Revenue Procedure 2015-3 to provide that, until the issue is resolved, the IRS will not provide letter rulings on whether the assets in a grantor trust receive a section 1014 basis adjustment at the death of the deemed owner of the trust for income tax purposes when those assets are not includible in the gross estate of that owner.

Notice 2015-44 publishes the inflation adjustment factor for the credit for carbon dioxide sequestration under section 45Q for calendar year 2015.