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June 9, 2023

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:


  • 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


Washington Dispatch for May 2023