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November 23, 2022

U.S. International Tax This Week for November 23

Ernst & Young's U.S. Tax This Week newsletter for the week ending November 23 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.


As cryptoassets took center stage in the mainstream media this week, the Internal Revenue Service (IRS) indicated it is continuing to move forward with getting a handle on issues and reporting, amid a dearth of guidance.

The IRS in October announced that it established a digital asset project office to address crypto issues. According to the new head of the office this week, "There was a recognition enterprise-wide that digital assets [are] big and that we should have a dedicated staff to address strategy, priorities, and then activities." The office will be staffed with seven full-time IRS employees, the official said. The official was quoted as saying the digital asset office will establish strategies and priorities over the coming 12 to 18 months.

The IRS reportedly is currently drafting questions on cryptocurrency and digital assets that will be added to corporate and partnership returns, including questions for individuals. The IRS began asking a crypto asset question on Form 1040 in 2019 but is now poised to begin collecting information from entities.

The IRS also released the 2020 Statistics of Income report on 18 November, showing that there was an almost 150% increase from 2019 to 2020, for taxpayers who checked "yes" on their returns in response to the question of whether they had cryptocurrency transactions. Over 2.3 million individual returns reported they had such transactions in 2020.

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.

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.

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.

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.

Recent Tax Alerts


— Nov 18: South Africa | Overview of new administrative penalties for late submission of personal tax returns (Tax Alert 2022-1742)


— Nov 21: Hong Kong introduces bill to refine its foreign source income exemption regime (Tax Alert 2022-1749)

— Nov 18: China's MLI will be applicable to certain payments as of 1 January 2023 (Tax Alert 2022-1733)

Canada & Latin America

— Nov 22: Colombian Congress approves tax reform bill (Tax Alert 2022-1757)


— Nov 22: Switzerland announces new quotas for Croatian nationals go into effect January 1, 2023 (Tax Alert 2022-1758)

— Nov 22: UK Prime Minister makes immigration-related announcements in November 21 speech (Tax Alert 2022-1756)

— Nov 18: UK announces new Electricity Generator Levy (Tax Alert 2022-1734)

Additional Resources

EY’s Tax News Update, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

EY’s Tax and Law Guides. — Tax and Law Guides | EY - Global is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

Because the matters covered herein are complicated, U.S. International 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.