09 June 2023

Washington Dispatch for May 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

Congress passes debt ceiling bill, averts possible default

  • US House Ways & Means Republicans introduce tax increase on foreign companies to influence global tax deal

    Treasury and IRS news

    IRS proposed regulations would turn off Section 367(d) following certain IP repatriations

  • IRS addresses taxation of digital currency

  • US officials comment on CAMT

  • IRS GLAM concludes FIRPTA regularly-traded-stock-exception test under Section 897(c)(3) applies at partnership level

    Tax treaties

    US negotiating tax agreements with Israel, Switzerland and Norway

    OECD developments 

    BEPS Pillar One to follow revised implementation plan

  • G7 Finance Ministers welcomed OECD progress report on tax cooperation, reiterated commitment to Pillars One and Two implementation

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    ATTACHMENT

    Washington Dispatch for May 2023

    Document ID: 2023-5497