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05 May 2023

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

    Document ID: 2023-5440

     
     

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