08 February 2023

Washington Dispatch for January 2023

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:

US Congress

  • Kevin McCarthy new House Speaker, Rep. Smith chairs Ways and Means Committee
  • JCT will release ‘Blue Book’ by end of June

Treasury and IRS news

  • Final regulations issued for qualified foreign pension funds contain some favorable clarifications
  • IRS proposed regulations would make major changes to domestically controlled QIE rules under Section 897, and certain controlled commercial entity rules under Section 892

IRS addresses deductions involving cryptocurrency in two CCA memos

  • Acting IRS Commissioner affirms continued participation in ICAP

    Transfer pricing

    IRS examiners must consult IRS Counsel before applying economic substance doctrine in transfer pricing audits

    ___________________________

    ATTACHMENT

    Washington Dispatch for January 2023

    Document ID: 2023-5165