EY ITTS Washington Dispatch, July 2024

Ernst & Young ITTS Washington Dispatch

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

US Congress begins August recess – US Supreme Court overrules Chevron deference to agency regulations – US appellate court rules NR’s gain from sale of its US partnership interest attributable to inventory is not US source income – IRS final Section 367(b) regs address certain cross-border triangular reorgs, inbound nonrecognition transactions – IRS officials offer update on CAMT, PTEP guidance – IRS and Medtronic file Eighth Circuit appellate briefs arguing for different transfer pricing methods – IRS official says corporations failing to respond to TP compliance letters referred for possible examination – G20 Finance Ministers, Central Bank Governors reiterate support for BEPS 2.0 – Inclusive Framework on BEPS finalizing MLC to implement Pillar One Amount A, Amount B consensus near – OECD releases sixth edition of Corporate Tax Statistics publication, Draft User Guide for GloBE Info Return XML Schema.