EY ITTS Washington Dispatch, December 2022

Ernst & Young ITTS Washington Dispatch

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

US, Croatia sign income tax treaty – IRS issues interim guidance on CAMT – IRS releases guidance on new stock buyback excise tax – IRS issues final revised QI agreement effective 2023 – IRS releases more guidance for brokers on transfers of PTP interests – IRS issues proposed rules on single-entity treatment of consolidated groups – FinCEN continues to extend certain FBAR signature authority reporting, releases proposed beneficial ownership regs – OECD releases public consultation document on Pillar One Amount A and DSTs – OECD releases consultation document on tax certainty for Pillar Two GloBE rules – OECD releases consultation document on Pillar Two GloBE Info Return – BEPS 2.0 document issued on safe harbors and penalty relief under Pillar Two GloBE rules – OECD releases public consultation document on Amount B of Pillar One on baseline marketing and distribution functions.