09 January 2024 Washington Dispatch for December 2023 The latest edition of EY'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: - IRS interim CAMT guidance provides relief from possible double-counting of CFC earnings in AFSI, but possible compliance burdens
- Treasury provides guidance on creditability of BEPS Pillar Two taxes, relief for pre-GloBE DCLs and extends temporary relief from FTC regs
- Interim guidance released on treatment of basis adjustments under Section 961(c) on inbound liquidation or asset reorganization
- US officials offer international regulatory update
- US Treasury announces entry into force of the US-Chile tax treaty
- IRS updates list of treaties
- US Supreme Court hears oral arguments in Moore transition tax case
- FASB modifies income tax disclosure rules
- US headquartered FG500 companies increase, reversing downward trend
- OECD/G20 IF releases BEPS Pillar Two GloBE rules guidance, new Pillar One MLC timeline
___________________________ Washington Dispatch for US distribution Global Washington Dispatch for global distribution Document ID: 2024-0148 |