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March 3, 2023
2023-0415

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

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Washington Dispatch for February 2023

 

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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