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