December 8, 2023 2023-2030 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
——————————————— ATTACHMENT Washington Dispatch for November 2023
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