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:

Legislation

• 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