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May 5, 2023
2023-5440

Washington Dispatch for April 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:

Legislation

  • House Republicans pass debt ceiling, spending bill; impasse continues 

IRS news

  • IRS provides transition period for documentation requirements for FTC ‘single country exception’

  • IRS updates crypto notice, virtual currency remains unavailable to generate FX gain or loss 

  • IRS addresses micro-captive transactions as listed transactions

  • IRS releases general plan for spending $80 million over the next 10 years 

Transfer pricing

  • IRS interim guidance on APA submissions fundamentally changes early stages of process 

Courts

  • US Tax Court rules IRS cannot assess penalties under Section 6038(b) for willfully failing to report foreign income

OECD developments 

  • OECD releases fifth annual peer review report on BEPS Action 6 on prevention of treaty abuse 

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ATTACHMENT

Washington Dispatch for April 2023

 
 

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