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December 8, 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:


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


  • 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


Washington Dispatch for November 2023