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September 1, 2022
2022-1328

Washington Dispatch for August 2022

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young's International Tax and Transaction Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:

Legislation

  • President Biden signs Inflation Reduction Act with 15% corporate minimum tax
  • Congress passes $280 billion Chips and Science Act

IRS news

  • Applicability date for foreign currency regulations under Section 987 extended again
  • IRS announces delay in effective date of Section 871(m) regulations

Transfer pricing news

  • Tax Court increases Medtronic royalty rate under unspecified TP method
  • Increased IRS funding from Inflation Reduction Act may increase scrutiny of transfer pricing cases

OECD developments

  • OECD releases 2022 update on peer review of preferential tax regimes and no or only nominal tax jurisdictions

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Washington Dispatch for August 2022

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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