Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

February 19, 2021

Report on recent US international tax developments 19 February 2021

US House Ways and Means Committee Chairman Richard Neal conceded this week that there is no consensus among Democrats in Congress on the approach to take in terms of United States (US) taxation of multinationals – some consider it a revenue source while others want to reexamine Tax Cuts and Jobs Act (TCJA) provisions. The Chairman added that in the end, “Congress will work closely with the administration to secure favorable outcomes for the U.S. businesses headquartered right here.”

On the topic of a corporate rate increase, Chairman Neal said harmonization of rates with the Organisation for Economic Co-operation and Development (OECD) makes some sense and, while nothing has been decided, the economic downturn “ought to cause us to be careful.” The Chairman also indicated that he objects to retroactive taxation and noted the importance of putting the pandemic and recession behind us.

He said it is clear after meeting with President Biden on 5 February that, as soon as the current round of coronavirus relief is put in place, Democrats plan to proceed with an infrastructure initiative that includes a revival of the Build America Bonds program.

Treasury Secretary Janet Yellen has suggested that a corporate tax rate increase to 28% could be proposed in what is expected to be the infrastructure-plus “Build Back Better” package, but the intention to pay for the bill has since become less certain. There are press reports that Biden Administration officials and congressional Democrats may be open to an infrastructure bill that does not include tax increases and is instead paid for with debt.

The Platform for Collaboration on Tax – a joint effort of the OECD, United Nations, International Monetary Fund and World Bank Group – recently released a toolkit designed to help developing countries with the successful implementation of effective transfer pricing documentation requirements. The toolkit compiles information on transfer pricing documentation and analyzes policy choices and legislative options. See EY Global Tax Alert, OECD, UN, IMF and World Bank Group present toolkit on the implementation of effective transfer pricing documentation requirements, dated 15 February 2021 for details. 

The OECD Forum on Tax Administration (FTA) on 18 February released a new handbook for the International Compliance Assurance Programme (ICAP), which for the first time is now open to all FTA administrations. The OECD describes ICAP as a voluntary program that provides for “coordinated risk assessment of large MNE groups by tax administrations in several jurisdictions using a group's Country-by-Country reports, master file, local files and other transfer pricing information.”

The OECD on 17 February also issued the 2021 Global Forum Capacity Building Report, laying out the Global Forum’s capacity-building program and outreach activities that were conducted in 2020. The Global Forum supports members “in tackling offshore tax evasion by monitoring, reviewing and assisting jurisdictions to implement international standards” related to tax transparency and exchange of information.


For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC

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.


Copyright © 2024, Ernst & Young LLP.


All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.


Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.


"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.


Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or Please refer to the privacy notice/policy on these sites for more information.

Yes, I accept         Find out more