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December 9, 2022
2022-1853

Washington Dispatch for November 2022

The latest edition of Ernst & Young'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:

Treasury and IRS news

  • IRS proposed foreign tax credit regulations offer relief from cost recovery and source-based attribution rules, include other key changes
  • IRS moving forward on cryptoasset issues
  • Section 367(d) regs coming early next year, official says
  • No delay or transition period for final Section 1446(f) regs implementation date

Tax treaty news

  • Congressional Republicans urge Administration to not terminate US-Hungary treaty

Transfer pricing

  • IRS will consider applying economic substance doctrine and related penalties more frequently in transfer pricing audits
  • IRS 2022–2023 Priority Guidance Plan includes transfer pricing projects similar to last year

OECD developments

  • OECD holds Tax Certainty Day addressing MAP developments, tax certainty under BEPS Pillars One and Two
  • OECD updates guidance on implementation of CbC Reporting

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Washington Dispatch for November 2022

 

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.

 

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