June 9, 2023 2023-1036 Washington Dispatch for May 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 - Congress passes debt ceiling bill, averts possible default
- US House Ways & Means Republicans introduce tax increase on foreign companies to influence global tax deal
IRS news - IRS proposed regulations would turn off Section 367(d) following certain IP repatriations
- IRS addresses taxation of digital currency
- US officials comment on CAMT
- IRS GLAM concludes FIRPTA regularly-traded-stock-exception test under Section 897(c)(3) applies at partnership level
Tax treaties - US negotiating tax agreements with Israel, Switzerland and Norway
OECD developments - BEPS Pillar One to follow revised implementation plan
- G7 Finance Ministers welcomed OECD progress report on tax cooperation, reiterated commitment to Pillars One and Two implementation
——————————————— ATTACHMENT Washington Dispatch for May 2023
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