taxnews.ey.comPrint

07 October 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

—————————————
ATTACHMENT

Document ID: 2022-1516

 

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.

 

Copyright © 1996 – 2025, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement