Ernst & Young ITTS Washington Dispatch

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition:

Biden Administration looks to scaled-back Build Back Better legislation – House Ways and Means Committee Republicans warn congressional consent needed for BEPS 2.0 Pillars – Final regulations released on treatment of domestic partnerships under Section 958, proposed PFIC regulations – IRS amends instructions for 2021 partnership Schedules K-2 and K-3, relevant to private equity, private capital funds – IRS announces fast-track pilot program to resolve corporate LTR requests in 12 weeks – US officials comment on cryptocurrency efforts – BEPS 2.0 model rules commentary expected to be released soon – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework – OECD publishes 2022 Transfer Pricing Guidelines – OECD releases eighth batch of Stage 2 peer review reports on dispute resolution.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition:

Biden Administration's Build Back Better legislation stalls in Congress; Senate Finance Committee releases updated international tax provisions – Senate Foreign Relations Committee Republicans urge vote on 2010 US-Chile tax treaty – Treasury releases final foreign tax credit regulations – IRS issues final rules on tax consequences of transition from LIBOR and other interbank offered rates in certain financial contracts – OECD releases Model Rules on Pillar Two Global Minimum Tax – OECD releases 2020 peer review report on BEPS Action 5 on Exchange of Information of Tax Rulings.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition:

US House passes Build Back Better Act budget reconciliation bill; action moves to Senate – President Biden signs infrastructure legislation including new cryptocurrency reporting – Final FTC regs expected by year-end, PTEP regs in 2022 – New IRS tool supports withholding agents' compliance with Form 1042-S – IRS requests comments on APA, MAP applications and compliance – US, Turkey announce joint statement on unilateral digital tax compromise – India, US agree on transitional approach for 2% Equalization Levy prior to implementation of Pillar One rule – OECD remains committed to BEPS Pillars in effect by end of 2023 – OECD releases 2020 MAP statistics and awards

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition:

President Biden releases pared down budget reconciliation framework – G20 leaders confirm commitment to global tax changes under BEPS 2.0 – Six country Joint Statement on transitional approach to existing unilateral DST measures released – IRS rules gains, losses from commodity hedges sourced by reference to underlying hedged inventory property – Final Section 987 foreign currency regulations, certain related final regulations deferred by one additional year – IRS maintaining policy on "telescoping" in APA and MAP cases – Cyprus clarifies US-Cyprus CAA for exchange of CbC reports – MLI Conference of the Parties issues two opinions re MAP implementation and arbitration rules – UN releases MAP and Tax Dispute Resolution Handbook

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress fails to pass infrastructure and budget reconciliation legislation -- House Ways & Means Committee reports out reconciliation bill with major international tax proposals --

Senate Finance Committee Chairman releases partnership tax proposals -- Final foreign tax credit regulations will include jurisdictional nexus requirement -- IRS allows taxpayer to reverse GILTI "gap period" transaction through late CTB election -- IRS articulates five-factor test in determining income inclusion of reimbursement payments -- IRS issues final regulations on treatment of QIP and provides guidance on foreign tax credits -- IRS seeing more billion-dollar MAP cases -- IRS lists jurisdictions with US information exchange agreements that allow reporting certain deposit interest -- G7 Finance Ministers make progress on BEPS 2.0 issues in lead-up to October 2021 meetings.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US infrastructure legislation, FY 2022 budget resolution move forward – Senate Finance Committee Chairman, members release international tax discussion draft – Finance Committee Chairman introduces bill to amend tax treatment of financial derivative transactions – Senate-passed infrastructure bill would impose information-reporting requirements on sales of cryptocurrency, other digital assets – IRS extends to 1 January 2023 date for W/H on certain transfers, distributions related to PTP interests – US, Germany agree on exchange of CbC reports – IRS financial services campaign will not target specific transactions – OECD releases 2021 peer review update of preferential tax regimes – OECD releases corporate tax statistics publication, including anonymized/aggregated CbC report stats.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: White House, Senate negotiators reach agreement on $1.2 trillion infrastructure package – OECD announces conceptual agreement in BEPS 2.0 project; endorsed by G20 Finance Ministers, Central Bank Governors – US, UK competent authorities sign agreements re treaty LOB provision – IRS memo addresses CSA and inclusion of stock-based compensation costs – US Treasury official provides international tax regulatory update.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Bipartisan infrastructure deal reached, but road to passage uncertain – House passes corporate disclosure package requiring CbC tax reporting for multinationals – Biden Administration's proposed 15% minimum tax could come with requirement to disclose book-tax differences – IRS announces plans to amend BEAT regarding qualified derivative payment reporting – G7 Finance Ministers express strong support for global tax changes under BEPS 2.0 – OECD publishes model rules for information exchange for digital platforms.

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury 'Green Book' offers new details on international tax proposals – Senate hearing discusses Biden Administration's international tax proposals – House bill would require SEC regulations on CbC financial information disclosure, including taxes – US proposes 15% global corporate minimum tax to BEPS 2.0 Steering Group – President Biden proposes increased IRS budget to improve tax compliance – IRS modifies guidance on accounting method changes for certain foreign corporations – IRS official comments on treaty derivative benefits post-Brexit – US Government releases early drafts of 2021 Schedules K-2 and K-3 for Forms 1065, 1120-S and 8865 – Parties to OECD MLI release interpretative guidance.

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The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury releases President's plan to overhaul corporate tax system – US Senators release proposed International Tax Framework – President Biden lays out $1.8 trillion American Families Plan proposal – Senate Finance Committee chairman reintroduces clean energy legislation – Treasury Secretary proffers BEPS 2.0 Pillar One proposal to Inclusive Framework – IRS issues proposed regs to coordinate WHT, gain deferral for certain foreign persons and partnerships investing in Qualified Opportunity Funds – IRS releases FAQs on ICAP program for US multinationals – PTEP guidance not expected until early fall – US, Japan reach agreement on tax treaty arbitration process – OECD releases consultation document with proposed changes to Commentaries to OECD Model Tax Convention on Article 9 (Associated Enterprises) – OECD publishes Arbitration Profiles for 30 countries under MLI – IMF and OECD release joint report on carbon pricing – UN tax committee approves new digital taxation article for UN model tax treaty – UN releases new Transfer Pricing Manual.