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06 October 2022

Washington Dispatch for September 2022

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:

Tax treaties

US treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates 

Treasury and IRS news

PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year

  • Treasury and IRS to issue proposed regulations on application of noncompulsory payment regs to certain amended Puerto Rico tax decrees

  • IRS Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation

    Transfer pricing news

    Sixth Circuit rules in favor of Eaton in appeal from Tax Court regarding APA cancellation 

    OECD developments

    OECD holds public consultation meeting on Progress Report on Amount A of BEPS Pillar One

  • OECD publishes Manual on Bilateral APAs

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    ATTACHMENT

    Washington Dispatch for September 2022

    Document ID: 2022-5951

     
     

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