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May 5, 2023
2023-0830

Washington Dispatch for April 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:

Legislation

  • House Republicans pass debt ceiling, spending bill; impasse continues 

IRS news

  • IRS provides transition period for documentation requirements for FTC ‘single country exception’
  • IRS updates crypto notice, virtual currency remains unavailable to generate FX gain or loss 
  • IRS addresses micro-captive transactions as listed transactions
  • IRS releases general plan for spending $80 million over the next 10 years 

Transfer pricing

  • IRS interim guidance on APA submissions fundamentally changes early stages of process 

Courts

  • US Tax Court rules IRS cannot assess penalties under Section 6038(b) for willfully failing to report foreign income

OECD developments 

  • OECD releases fifth annual peer review report on BEPS Action 6 on prevention of treaty abuse 

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Washington Dispatch for April 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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