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
——————————————— ATTACHMENT Washington Dispatch for April 2023 
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