EY ITTS Washington Dispatch, January 2023
Release Date:
A monthly review of US international tax-related developments. In this edition: Kevin McCarthy new US House Speaker, Rep. Smith chairs Ways and Means Committee – JCT to release ‘Blue Book’ on tax legislation by end of June – IRS issues final regulations for qualified foreign pension funds – IRS releases proposed regs on domestically controlled QIE rules under Section 897, certain controlled commercial entity rules under Section 892 – IRS addresses deductions involving cryptocurrency in two CCA memos – IRS to continue participation in ICAP – IRS examiners must consult IRS counsel to apply economic substance doctrine in transfer pricing audits.
EY ITTS Washington Dispatch, January 2023