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11 August 2024

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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Attachments

Washington Dispatch for US distribution

Global Washington Dispatch for global distribution

Document ID: 2024-1524

 

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