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:

Treaty news

• United States, Croatia sign income tax treaty

Treasury and IRS news

• IRS issues interim guidance on application of new corporate alternative minimum tax
• IRS releases guidance on new stock buyback excise tax
• IRS issues final revised qualified intermediary agreements effective beginning in 2023
• IRS releases additional guidance for brokers on transfers of interests in publicly traded partnerships
• IRS issues proposed rules on single-entity treatment of consolidated groups
• FinCEN continues to extend certain signature authority reporting (FBAR, Form 114)

OECD developments

• OECD releases public consultation document on Pillar One Amount A and Digital Services Taxes
• OECD releases consultation document on tax certainty for the Pillar Two GloBE rules
• OECD releases consultation document on Pillar Two GloBE Information Return
• OECD/G20 Inclusive Framework releases document on safe harbors and penalty relief under Pillar Two GloBE rules
• OECD releases public consultation document on Amount B of Pillar One on baseline marketing and distribution functions
• OECD's 2021 MAP statistics show US continues to decrease case inventory
• OECD releases corporate tax statistics and the 2022 revenue statistics and consumption tax trends

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ATTACHMENT

Washington Dispatch for December 2022