August 11, 2024 2024-1524 Washington Dispatch for July 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 Congress begins August recess
Courts - US Supreme Court overrules Chevron deference to agency regulations
- US appellate court rules nonresident's gain from sale of its US partnership interest attributable to inventory is not US source income
IRS news - Final Section 367(b) regulations address certain cross-border triangular reorgs and inbound non-recognition transactions
- IRS officials offer update on CAMT, PTEP guidance
Transfer pricing - IRS and Medtronic file appellate briefs in Eighth Circuit appeal arguing for different transfer pricing methods
- IRS representative says corporations that failed to respond to transfer pricing compliance letters have been referred for possible examination
OECD developments - G20 Finance Ministers, Central Bank Governors reiterate support for BEPS 2.0
- Inclusive Framework on BEPS finalizing MLC to implement Pillar One Amount A, Amount B consensus near
- OECD releases sixth edition of Corporate Tax Statistics publication
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