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March 23, 2023

U.S. Tax This Week for March 24

Ernst & Young's U.S. Tax This Week newsletter for the week ending March 24 is now available. Prepared by Ernst & Young's National Tax Department in Washington, D.C., this weekly update summarizes important news, cases, and other developments in U.S. taxation.

Top of the Week

FY2024 Budget includes few new international tax proposals, largely reprising proposals from prior budgets

In its FY2024 explanation of the Biden Administration's revenue proposals (Greenbook), the United States (US) Treasury offers a few new international tax proposals as part of the administration's FY 2024 Budget (Budget). Most proposals in this year's Budget appeared in prior budget proposals or proposed legislation. The proposals have various effective dates. While the prospects for enactment are dim this year, taxpayers should familiarize themselves with these proposals in case they appear as revenue offsets in later legislation. EY Tax Alert 2023-0509 has details.

OECD updates to MAP and APA guidance have implications for US multinationals

The Organisation for Economic Cooperation and Development (OECD) released two items of guidance that will help US multinationals with the processes necessary for tax certainty in transfer pricing transactions: (1) a revised methodology for Base Erosion and Profit Shifting (BEPS) Action 14 peer reviews and updates on reporting of Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) statistics; and (2) a manual on Multilateral Mutual Agreement Procedures and Advance Pricing Agreements (see Tax Alerts 2023-0322 and 2023-0355). The IRS has publicly stated that it is updating the MAP and APA guidance in its revenue procedures. EY Tax Alert 2023-0524 has details.

Upcoming Webcasts

How recent developments potentially impact cross-border tax controversy procedures and processes (March 30)
During this EY Webcast, Ernst & Young professionals will share emerging trends in cross-border controversy. They will also discuss the OECD’s recently published Bilateral APA Manual (BAPAM), Manual on the Handling of Multinational MAPs and APAs (MoMA), and the revised BEPS Action 14 review process.

What to know about the 2023 EY Tax risk and controversy survey results — Americas and Europe (April 5)
During this EY Webcast, Ernst & Young professionals will explore how taxpayers perceive and manage tax risk and controversy in 2023.

Tax in a time of transition: Legislative, economic, regulatory and IRS developments (April 21)
During this EY Webcast, Ernst & Young professionals will provide updates on: (i) the US economy and tax policy; (ii) what’s happening at the IRS; and (iii) breaking developments.

US corporate income tax compliance: Tax year 2022 readiness and planning for what’s next and beyond (April 26)
During this EY Webcast, Ernst & Young professionals will discuss how companies can continue to navigate the complexity and challenges of the ever-changing tax compliance landscape, while preparing for tax year 2022 and beyond.

Recent Tax Alerts

Internal Revenue Service

— Mar 21: IRS TE/GE officials discuss key issues, accomplishments in FY 2022, and examinations priorities (Tax Alert 2023-0536)

— Mar 21: Tax M&A Update for February 2023 (Tax Alert 2023-0530)

— Mar 17: QUEST Economic Update highlights key US and global economic trends - March 17, 2023 (Tax Alert 2023-0511)


— Mar 22: Costa Rican Tax Authority creates National Large Taxpayers Dialogue Forum (Tax Alert 2023-0547)

— Mar 22: Costa Rican authorities amend Joint Resolution for Transparency and Beneficial Owner Register (Tax Alert 2023-0546)

— Mar 22: Honduran Government to file new tax reform before the National Congress (Tax Alert 2023-0545)

— Mar 22: Luxembourg submits draft legislation introducing public country-by-country reporting for multinational enterprises (Tax Alert 2023-0542)

— Mar 22: Council of Ministers of Economic Integration of Central America establishes US$3 charge for each DUCA-F transmitted through the SIECA platforms (Tax Alert 2023-0541)

— Mar 22: Germany Federal Ministry of Finance publishes draft BEPS 2.0 Pillar Two implementation bill (Tax Alert 2023-0540)

— Mar 22: UAE issues additional guidance on determination of tax residency for individuals (Tax Alert 2023-0539)

— Mar 22: EY Tax articles discuss how BEPS 2.0 may impact your operations (Tax Alert 2023-0538)

— Mar 21: The Latest on BEPS and Beyond | March 2023 (Tax Alert 2023-0537)

— Mar 21: Spain's Large Business Unit to now accept only digital signatures for work and residence permit applications (Tax Alert 2023-0535)

— Mar 21: China Mainland eases travel restrictions and reinstates certain visa-free policies (Tax Alert 2023-0534)

— Mar 21: USCIS announces mail delivery process for receiving ADIT (I-551) stamp (Tax Alert 2023-0533)

— Mar 20: Nigeria's Tax Appeal Tribunal rules that network facilities/infrastructure providers should not be subject to the National Information Technology Development Act levy (Tax Alert 2023-0526)

— Mar 20: OECD updates to MAP and APA guidance have implications for US multinationals (Tax Alert 2023-0524)

— Mar 20: Uruguayan Tax Office clarifies substance requirements applicable to the Corporate Income Tax's source criteria (Tax Alert 2023-0521)

— Mar 20: Cyprus Tax Authority publishes 10-year government bond yield rates for NID purposes (Tax Alert 2023-0516)

— Mar 17: Australian Treasury releases Exposure Draft Bills on thin cap changes and tax transparency disclosure of information (Tax Alert 2023-0510)

— Mar 17: UK increases Plastic Packaging Tax rate (Tax Alert 2023-0506)


— Mar 22: What to expect in Washington (March 22) (Tax Alert 2023-0544)

— Mar 21: Biden Administration's budget proposes significant tax increases on businesses and high-net-worth individuals (Tax Alert 2023-0532)

— Mar 20: President Biden's FY 2024 budget proposes many changes affecting employers and employees (Tax Alert 2023-0514)

— Mar 17: FY2024 Budget includes few new international tax proposals, largely reprising proposals from prior budgets (Tax Alert 2023-0509)


— Mar 20: West Virginia issues revised 2023 withholding tables and formulas for immediate use by employers (Tax Alert 2023-0527)

IRS Weekly Wrap-Up

Proposed Regulations

 REG-120653-22Advanced Manufacturing Investment Credit


 2023-27Treatment of certain nonfungible tokens as collectibles

Internal Revenue Bulletin

 2023-12Internal Revenue Bulletin of March 20, 2023

Because the matters covered herein are complicated, U.S. Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.