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08 December 2023

Washington Dispatch for November 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

  • US Congress approves new CR, complicates options for year-end tax bil
  • House Ways and Means Committee clears US-Taiwan tax bill

Courts

  • Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership withholding tax
  • US court denies DRD after applying economic substance doctrine

Treasury and IRS news

  • IRS issues proposed regulations on QBUs, including simplified elections for determining Section 987 gain or loss but restrictions on loss recognition

OECD developments

  • OECD, country officials discuss BEPS 2.0 Pillars One and Two and other OECD tax work
  • OECD announces 48 jurisdictions to implement CARF by 2027

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ATTACHMENT

Washington Dispatch for November 2023

Document ID: 2023-2030

 

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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