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09 December 2022

Washington Dispatch for November 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:

Treasury and IRS news

IRS proposed foreign tax credit regulations offer relief from cost recovery and source-based attribution rules, include other key changes 

  • IRS moving forward on cryptoasset issues

  • Section 367(d) regs coming early next year, official says

  • No delay or transition period for final Section 1446(f) regs implementation date

    Tax treaty news

    Congressional Republicans urge Administration to not terminate US-Hungary treaty

    Transfer pricing news

    IRS will consider applying economic substance doctrine and related penalties more frequently in transfer pricing audits 

  • IRS 2022–2023 Priority Guidance Plan includes transfer pricing projects similar to last year 

    OECD developments

    OECD holds Tax Certainty Day addressing MAP developments, tax certainty under BEPS Pillars One and Two

  • OECD updates guidance on implementation of CbC Reporting

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    ATTACHMENT

    Washington Dispatch for November 2022

    Document ID: 2022-6192

     
     

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