November 8, 2023
2023-1853 Washington Dispatch for October 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: Top story - OECD releases text of Amount A Pillar One MLC, Treasury announces consultation
US Congress - House of representatives elects new Speaker
- US-Taiwan legislation moves forward
IRS news - IRS proposed regulations would amend Section 367(b) regulations applying to certain cross-border triangular reorgs, inbound nonrecognition transactions
- US officials offer update on pending guidance
- IRS informing taxpayers of Schedule UTP non-compliance
- IRS sending compliance alerts to US subs of foreign-owned corporations
- IRS to broaden scope of corporate PLRs
Tax treaties - US-Chile tax treaty’s US reservations reflect current policy
Transfer pricing - IRS appeals Tax Court’s latest decision in Medtronic
- US, Israel sign CAA on exchange of CbC reports
- Cyprus issues clarification note on future CbC exchange agreement with US
OECD developments - OECD/G20 Inclusive Framework launches Multilateral Convention to implement Pillar Two Subject to Tax Rule
- BEPS IF considering Pillar Two guidance on deferred tax assets
- OECD FTA agrees on action to support continued digital transformation, delivering Pillar Two and capacity building
- OECD releases outcomes of sixth peer review on BEPS Action 13 on CbCR
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ATTACHMENT Washington Dispatch for October 2023 
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