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October 7, 2022

Washington Dispatch for September 2022

The latest edition of EY'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:

Tax treaties

  • US treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates

Treasury and IRS news

  • PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year
  • Treasury and IRS to issue proposed regulations on application of noncompulsory payment regs to certain amended Puerto Rico tax decrees
  • IRS Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation

Transfer pricing news

  • Sixth Circuit rules in favor of Eaton in appeal from Tax Court regarding APA cancellation

OECD developments

  • OECD holds public consultation meeting on Progress Report on Amount A of BEPS Pillar One
  • OECD publishes Manual on Bilateral APAs