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January 11, 2023
2023-0067

Washington Dispatch for December 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:

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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Washington Dispatch for December 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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