EY ITTS Washington Dispatch, April 2024

Ernst & Young ITTS Washington Dispatch

A monthly review of US international tax-related developments. In this edition:

US tax policy battle lines being drawn; House Republican tax writers form 10 TCJA ‘tax teams’ – US progress on global minimum tax will positively affect ongoing R&D talks, JCT updating BEPS Pillar Two analysis – IRS releases proposed rules on stock repurchase excise tax – IRS waives penalty for CAMT estimated tax – IRS final regulations on FIRPTA controlled QIE rules released – IRS releases draft Form 1099-DA on digital asset proceeds – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – IRS releases APA report for 2023 – OECD BEPS 2.0 status update – OECD releases consolidated GloBE commentary document, revised GloBE examples.