EY ITTS Washington Dispatch, November 2023

Ernst & Young ITTS Washington Dispatch

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

US Congress approves new CR, complicates options for year-end tax bill – House Ways and Means Committee clears US-Taiwan tax bill – Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership WHT – US court denies DRD after applying economic substance doctrine – IRS issues proposed regs on QBUs, including simplified elections for determining Section 987 gain or loss but restrictions on loss recognition – OECD, country officials discuss BEPS 2.0 Pillars One and Two.