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November 20, 2022

U.S. Tax This Week for November 18

Ernst & Young's U.S. Tax This Week newsletter for the week ending November 18 is now available. Prepared by Ernst & Young's National Tax Department in Washington, D.C., this weekly update summarizes important news, cases, and other developments in U.S. taxation.

Top of the Week

IRS and Treasury issue 2022 - 2023 Priority Guidance Plan, addressing various accounting method issues

The IRS and Treasury have issued the 2022 — 2023 Priority Guidance Plan, addressing various accounting method issues as well as other provisions. The plan includes 205 guidance projects, which the Treasury and IRS are seeking to complete by June 30, 2023. EY Tax Alert 2022-1715 has details.

UK Chancellor delivers Autumn Statement

On 17 November, the United Kingdom (UK) Chancellor, Jeremy Hunt, delivered his Autumn Statement. In opening his Statement, he said that in order to deal with unprecedented global headwinds, his focus would be on stability, growth and public services. EY Tax Alert 2022-1727 has details.

Upcoming Webcasts

New proposed foreign tax credit regulations: what changed, what didn’t, and what could it all mean for your company? (December 1)
During this EY Webcast, Ernst & Young professionals will give an update on the newly released proposed foreign tax credit regulations. The proposed regulations make several changes to address issues identified in the December 2021 final foreign tax credit regulations. Those final foreign tax credit regulations significantly changed the rules on determining what is a creditable foreign income tax; some of these changes had the potential to render many long-standing creditable taxes noncreditable.

2022 year-end tax considerations and other hot topics for asset managers (December 5)
In a year filled with economic uncertainty and global political changes, year-end tax planning takes on elevated importance for asset managers. Issues at the federal, state, and local levels will play an important role in year-end planning and reporting. During this EY Webcast, Ernst & Young professionals will discuss what it may mean for asset managers and their investors.

How to navigate information requests in transfer pricing audits (December 6)
During this EY Webcast, Ernst & Young professionals will address various cross-border controversy topics and feature insights from professionals around the globe.

Domestic tax quarterly webcast series - A focus on state tax matters (December 7)
During this EY Webcast, please join our panel of Ernst & Young professionals for a discussion on the top-of-mind issues impacting state and local taxes.

Global Treasury: Key tax trends and topics to consider for 2023 (December 8)
During this EY Webcast, Ernst & Young professionals will discuss key tax trends and topics that will affect global treasury activity in 2023. This session will cover, in particular, multinationals’ cash management and risk management activities, as well as the potential effect of Pillar Two and the trends in financial transaction transfer pricing controversy.

2022 employment tax year in review (December 8)
During this EY Webcast, Ernst & Young professionals will discuss several common areas of year-end payroll and employment tax concerns.

Accounting for income taxes - a quarterly perspective (December 13)
During this EY Webcast, Ernst & Young professionals, moderated by Angela Evans, Partner, Tax Accounting and Risk Advisory Services (TARAS), will discuss ongoing issues and regulatory trends in the tax accounting arena. Topics will include recent tax legislation with tax accounting implications and a review of current income tax accounting concepts.

Omnishoring: Recent trends in supply chain, tax and global trade (December 13)
During this EY Webcast, Ernst & Young professionals will discuss the current factors that affect supply chain. This session will cover the macroeconomic, geopolitical and operational trends driving multinationals to reconsider the resilience of their supply chain across the manufacturing, logistics, distribution and sales functions.

ax in the time of COVID-19: update on legislative, economic, regulatory and IRS developmentse (December 16)
During this EY Webcast, Ernst & Young professionals will discuss how businesses can navigate the tax policy environment and continue to effectively operate their tax function in this time of crisis and change. Panelists will provide updates on: (i) the US economy and tax policy; (ii) breaking developments; and (iii) what’s happening at the IRS

Recent Tax Alerts

Internal Revenue Service

— Nov 15: IRS and Treasury issue 2022 - 2023 Priority Guidance Plan, addressing various accounting method issues (Tax Alert 2022-1715)

— Nov 14: IRS announces rate increase for renewable electricity production credit based on Inflation Reduction Act amendments (Tax Alert 2022-1709)

— Nov 11: IRS 2022–2023 Priority Guidance Plan includes transfer pricing projects similar to last year (Tax Alert 2022-1704)

— Nov 10: FY2023 priorities for IRS Tax Exempt & Government Entities division provided in annual Priority Guidance Plan and TE/GE Program Letter (Tax Alert 2022-1693)


— Nov 17: UK Chancellor delivers Autumn Statement (Tax Alert 2022-1727)

— Nov 17: Global Tax Policy and Controversy Watch | November 2022 edition (Tax Alert 2022-1726)

— Nov 16: UAE issues resolution on tax residency (Tax Alert 2022-1723)

— Nov 16: Israeli court rules IP value is six times higher (Tax Alert 2022-1721)

— Nov 16: Malta launches new “Startup Residence Programme” for business founders and core employees (Tax Alert 2022-1718)

— Nov 15: Government of Canada announces withdrawal of Most-Favored-Nation tariff benefit on goods originating in Russia and Belarus (Tax Alert 2022-1714)

— Nov 15: The Latest on BEPS and Beyond | November 2022 (Tax Alert 2022-1713)

— Nov 15: China Mainland relaxes COVID-19-related travel restrictions (Tax Alert 2022-1711)

— Nov 14: Argentine Lower House of Congress approves Budget bill for 2023 (Tax Alert 2022-1710)

— Nov 11: Australia announces reshaping skilled migration and resetting processing priorities (Tax Alert 2022-1702)

— Nov 11: New Zealand's minimum wage threshold to increase while reform remains a work in progress (Tax Alert 2022-1701)

— Nov 11: Canada's revised EIFEL proposals discussed (Tax Alert 2022-1699)

— Nov 11: Argentine Commission on Foreign Affairs approves bill to ratify MLI (Tax Alert 2022-1697)


— Nov 18: What to expect in Washington (November 18) (Tax Alert 2022-1735)


— Nov 17: 2022 FUTA credit reduction to apply in five jurisdictions (Tax Alert 2022-1728)

— Nov 17: New Hampshire positive-balanced employers' SUI tax rates continue at base rates for second-quarter 2022 (Tax Alert 2022-1725)

Recent Newsletters

State and Local Tax Weekly
   Highlights of this edition include:

Treasury announces $5 billion award for New Markets Tax Credit program for CY 2021. On Oct. 28, 2022, the Treasury Department announced that it awarded $5 billion in New Markets Tax Credit (NMTC) allocations to successful Community Development Entities (CDEs) from the 2021 application round. The $5 billion was awarded to 107 CDEs headquartered in 35 states and the District of Columbia.

— Income/Franchise, Sales & Use, Business Incentives, Property Tax, Compliance & Reporting, Payroll & Employment Tax, Value Added Tax, Upcoming Webcasts

IRS Weekly Wrap-Up


 TD 9967Section 42, Low-Income Housing Credit Average Income Test Regulations; Correction
 TD 9947Section 199A Rules for Cooperatives and Their Patrons; Correction


 2022-59Sections 4375 & 4376 – Insured and Self-Insured Health Plans Adjusted Applicable Dollar Amount for Fee Imposed by Sections 4375 and 4376
 2022-60Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates

Internal Revenue Bulletin

 2022-47Internal Revenue Bulletin of November 21, 2022

Because the matters covered herein are complicated, U.S. Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.