May 10, 2024 2024-0950 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: 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
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