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May 10, 2024

Washington Dispatch for April 2024

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:


  • US tax policy battle lines are being drawn; House tax writers form 10 TCJA 'tax teams'
  • US progress on global minimum tax will positively affect ongoing R&D talks, JCT updating BEPS Pillar Two analysis

Treasury and IRS news

  • IRS releases proposed rules on stock repurchase excise tax; follows earlier guidance with some modifications, including to funding rule, redemptions
  • IRS waives penalty for CAMT estimated tax
  • IRS final regulations on FIRPTA controlled QIE rules released
  • IRS releases draft Form 1099-DA on digital asset proceeds
  • US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty

Transfer pricing news

  • APA report for 2023 shows number of APAs executed more than doubled

OECD developments

  • OECD BEPS 2.0 update
  • OECD releases consolidated GloBE commentary document, revised GloBE examples
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Washington Dispatch for US distribution

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