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October 8, 2021

Washington Dispatch for September 2021

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young's International Tax and Transaction Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:


  • 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

Treasury and IRS news

  • Final foreign tax credit regulations will include jurisdictional nexus requirement, Treasury official says
  • 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 qualified improvement property 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 of certain deposit interest

OECD Developments

  • G7 Finance Ministers make progress on BEPS 2.0 issues in lead-up to October 2021 meetings


Washington Dispatch for September 2021


The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.


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