08 December 2023

Washington Dispatch for November 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

US Congress approves new CR, complicates options for year-end tax bill

  • House Ways and Means Committee clears US-Taiwan tax bill 

    Courts

    Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership withholding tax

  • US court denies DRD after applying economic substance doctrine

    Treasury and IRS news

    IRS issues proposed regulations on QBUs, including simplified elections for determining Section 987 gain or loss but restrictions on loss recognition

    OECD developments

    OECD, country officials discuss BEPS 2.0 Pillars One and Two and other OECD tax work

  • OECD announces 48 jurisdictions to implement CARF by 2027

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    ATTACHMENT

    Washington Dispatch for November 2023

    Document ID: 2023-5720