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03 March 2023

Washington Dispatch for February 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

President Biden delivers State of the Union address, proposes fourfold increase in stock buyback excise tax, ‘billionaire surtax’ 

  • House Ways and Means Committee Chairman calls BEPS Undertaxed Profits Rule ‘fundamentally flawed’

    Treasury and IRS news

    Proposed PTEP regulations to be released in latter half of 2023

  • IRS addresses deductions involving cryptocurrency in two Chief Counsel Advice memos

    Transfer pricing

    US Tax Court approves IRS/Eaton Corporation agreement resolving APA cancellation case

    OECD developments 

    OECD releases additional administrative guidance on BEPS 2.0 Pillar Two

  • OECD’s Pillar Two administrative guidance raises implications for US multinationals

  • OECD releases revised methodology for BEPS Action 14 peer reviews, updates on reporting of MAP and APA statistics

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    ATTACHMENT

    Washington Dispatch for February 2023

    Document ID: 2023-5260

     
     

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