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January 9, 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:

Treasury and IRS news

  • 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

Tax treaties

  • 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

Tax accounting

  • FASB modifies income tax disclosure rules

In case you missed it…

  • US headquartered FG500 companies increase, reversing downward trend

OECD developments

  • 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