Daily Tax Update - November 21, 2014: OECD Issues Discussion Draft on Preventing Treaty Abuse

OECD Issues Discussion Draft on Preventing Treaty Abuse: Today, the OECD released a discussion draft on the prevention of treaty abuse.  The discussion draft contains follow-up work on Action 6 (“preventing the granting of treaty benefits in inappropriate circumstances”) of the Base Erosion and Profit Shifting (BEPS) Action Plan.  Specifically, it addresses the limitation on benefits provisions of the OECD model treaty as well as issues related to the treaty entitlement of collective investment vehicles (CIVs) and non-CIV funds.  The discussion draft also looks at issues related to the principal purpose test. 

IRS Issues Guidance on the Use of Electronic Media for Employee Transportation Benefits:  The IRS issued Rev. Rul. 2014-32, which provides guidance on the use of smartcards, debit or credit cards, or other electronic media to provide qualified transportation fringe benefits to employees.