07 May 2021

Washington Dispatch for April 2021

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

Legislation

US Treasury releases President’s plan to overhaul corporate tax system 

  • Senators Wyden, Brown and Warner release International Tax Framework

  • President Biden lays out $1.8 trillion American Families Plan proposal

  • Senate Finance Committee chairman reintroduces clean energy legislation

    Digital Taxation

    Treasury Secretary proffers BEPS 2.0 Pillar One proposal to Inclusive Framework

    IRS news

    IRS issues proposed regs to coordinate WHT and gain deferral for certain foreign persons and partnerships investing in QOFs, clarify working capital safe harbor

  • IRS releases FAQs on ICAP program for US multinational enterprises

  • IRS extends time for submitting APA and MAP requests with e-signatures

    OECD developments

    OECD releases consultation document with proposed changes to Commentaries to OECD Model Tax Convention on Article 9 (Associated Enterprises) and related articles

  • OECD publishes Arbitration Profiles for 30 countries under MLI, clarifies entry into effect

  • OECD releases fourth batch of Stage 2 peer review reports on dispute resolution

  • OECD releases third annual peer review report and revised peer review documents on BEPS Action 6 relating to prevention of treaty abuse

    United Nations

    UN tax committee approves new digital taxation article for UN model tax treaty

  • UN releases new Transfer Pricing Manual

    ———————————————
    ATTACHMENT

    Washington Dispatch for April 2021

    Document ID: 2021-5528