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December 9, 2022

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


Washington Dispatch for November 2022