EY Cross-Border Taxation Spotlight for Week ending 10 November 2023
A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.