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February 8, 2023

Washington Dispatch for January 2023

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:

US Congress

  • Kevin McCarthy new House Speaker, Rep. Smith chairs Ways and Means Committee
  • JCT will release ‘Blue Book’ by end of June

Treasury and IRS news

  • Final regulations issued for qualified foreign pension funds contain some favorable clarifications
  • IRS proposed regulations would make major changes to domestically controlled QIE rules under Section 897, and certain controlled commercial entity rules under Section 892
  • IRS addresses deductions involving cryptocurrency in two CCA memos
  • Acting IRS Commissioner affirms continued participation in ICAP

Transfer pricing

  • IRS examiners must consult IRS Counsel before applying economic substance doctrine in transfer pricing audits


Washington Dispatch for January 2023