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December 4, 2022

U.S. International Tax This Week for December 2

Ernst & Young's U.S. International Tax This Week newsletter for the week ending December 2 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.


The House and Senate this week returned from the Thanksgiving break for the final stretch of the congressional lame-duck session with much uncertainty, including how to extend government funding beyond 16 December. There have been negotiations on an omnibus appropriations measure to extend funding through the end of the fiscal year ending 30 September 2023, which could possibly include tax, retirement, and health items. A lack of progress will increase the possibility that Congress will instead pass a continuing resolution (CR) to fund the government until 23 December (if an omnibus bill is on the horizon), or a CR extending into the next year at which point there will be a new Republican House majority.

Congressional leaders of both parties this week reportedly agreed to try and craft an omnibus spending bill before the end of the year. Senate Majority Leader Chuck Schumer was quoted as saying on 29 November: "We have agreed — the four leaders and the four heads of the Appropriations committees — to sit down very shortly and begin thrashing out how we can come together and get an omnibus done." In addition to the Senate Majority Leader, the four leaders include House Speaker Nancy Pelosi, Senate Minority Leader Mitch McConnell and House Minority Leader Kevin McCarthy.

If a deal can be reached on an omnibus spending bill, inclusion of a tax package with business tax provisions — addressing the IRC Sections 174 research and development and 163(j) interest deduction Tax Cuts and Jobs Act cliffs, tax extenders, and other items — could come down to whether the parties can agree on some expansion of the Child Tax Credit, which Democrats have insisted must accompany any business tax measures.

A Treasury official this week did not rule out the possibility that it may issue some form of guidance for the new corporate alternative minimum tax (CAMT), enacted as part of the Inflation Reduction Act (IRA), before the end of the year. The official confirmed that any initial guidance would address critical issues but declined to say what that would include or the form of that guidance. He further was quoted as saying that while guidance for the CAMT and the stock buyback provisions are a high priority, in Treasury's eyes they take a backseat to the IRA's green energy incentives, although he noted these are different work streams and any prioritization would take place during the clearance process.

Upcoming Webcasts

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.

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.

Tax 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


— Dec 01: Ethiopia introduces social welfare levy on imported goods (Tax Alert 2022-1786)

— Nov 30: Tax highlights of Ghana's 2023 Budget Statement and Economic Policy provided (Tax Alert 2022-1780)

— Nov 28: Kenya begins implementation of the Nairobi International Financial Center regime (Tax Alert 2022-1767)


— Nov 23: Malaysia to issue new ePASS upon renewal of Employment and Dependent Passes (Tax Alert 2022-1760)

Canada & Latin America

— Dec 01: Ontario Immigrant Nominee Program (OINP) updates selection factors under Expression of Interest system (Tax Alert 2022-1790)

— Dec 01: Ontario launches Immigrant Nominee Program (OINP) Entrepreneur Success Initiative (Tax Alert 2022-1789)

— Dec 01: EY Canada's Tax Matters @ EY for December 2022 (Tax Alert 2022-1785)

— Nov 30: Uruguay establishes conditions for employees to work remotely under Free Trade Zone regime (Tax Alert 2022-1779)

— Nov 28: Mexico publishes MLI in Federal Official Gazette; timeline for entry into force will be triggered once instrument of ratification is deposited with OECD (Tax Alert 2022-1766)

— Nov 23: Ecuador enacts new regulations on Income Tax, including lower income tax rates for new investments (Tax Alert 2022-1762)


— Nov 29: Spanish Tax Authority announces opening of registration site for new plastic packaging tax as of 1 December 2022 (Tax Alert 2022-1771)

— Nov 28: Italian Government approves 2023 Budget draft document and proposes further suspension of Sugar Tax and Plastic Tax for 2023 (Tax Alert 2022-1768)


— Dec 01: OECD holds Tax Certainty Day addressing MAP developments and tax certainty under Pillars One and Two (Tax Alert 2022-1788)

IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2022-48Internal Revenue Bulletin of November 28, 2022
 2022-49Internal Revenue Bulletin of December 5, 2022

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.