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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

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Washington Dispatch for May 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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