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March 3, 2023

Washington Dispatch for February 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

  • President Biden delivers State of the Union address, proposes fourfold increase in stock buyback excise tax, ‘billionaire surtax’ 
  • House Ways and Means Committee Chairman calls BEPS Undertaxed Profits Rule ‘fundamentally flawed’

Treasury and IRS news

  • Proposed PTEP regulations to be released in latter half of 2023
  • IRS addresses deductions involving cryptocurrency in two Chief Counsel Advice memos

Transfer pricing

  • US Tax Court approves IRS/Eaton Corporation agreement resolving APA cancellation case

OECD developments 

  • OECD releases additional administrative guidance on BEPS 2.0 Pillar Two
  • OECD’s Pillar Two administrative guidance raises implications for US multinationals
  • OECD releases revised methodology for BEPS Action 14 peer reviews, updates on reporting of MAP and APA statistics


Washington Dispatch for February 2023