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June 6, 2024

Washington Dispatch for May 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:


  • House Republicans prepare for TCJA ‘cliffs’
  • White House official previews President Biden’s tax policy if he wins second term
  • US House Ways and Means Chairman, Treasury Secretary spar over TCJA, BEPS 2.0
  • US will not sign BEPS Pillar One MLC without India, China TP resolution

IRS news

  • IRS provides further transitional relief under IRC Section 871(m) for treatment of dividend equivalents
  • IRS to defer applicability date of some provisions in IRC Sections 59A and 6038A regs for qualified derivative payments
  • New updated procedures for IRC Section 355 transaction PLRs released
  • CAMT regs in advanced stage, Treasury official says
  • Final crypto reporting rules coming in 2024
  • IRS proposed regulations would expand guidance on foreign trusts and large foreign gifts

OECD developments

  • More OECD BEPS 2.0 GloBE guidance coming
  • BEPS Pillar One MLC on track for signature in June, official says
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