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November 9, 2021

Washington Dispatch for October 2021

The latest edition of EY'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:


  • President Biden releases pared down budget reconciliation framework 

Digital economy

  • G20 leaders confirm commitment to global tax changes under BEPS 2.0 

  • Six country Joint Statement on transitional approach to existing unilateral measures during period before Pillar One is in effect

Treasury and IRS news

  • IRS rules gains and losses arising from commodity hedges may be sourced by reference to the underlying hedged inventory property

  • IRS revises Forms W-8ECI, W-8BEN-E, W-8BEN 

  • FinCEN provides FBAR relief to victims of recent natural disasters giving them until 31 December 2021 to file 

Transfer pricing news

  • IRS maintaining policy on 'telescoping' in APA and MAP cases while trying to alleviate administrative burden, official says

  • Cyprus clarifies US-Cyprus CAA for exchange of CbC reports 

OECD Developments

  • MLI Conference of the Parties issues two opinions re MAP implementation and entry into effect of arbitration rules

  • OECD releases outcomes of fourth phase of peer reviews on BEPS Action 13

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

  • OECD releases PRC Stage 2 peer review report on implementation of Action 14 minimum standard

United Nations

  • UN releases MAP and Tax Dispute Resolution Handbook 


Washington Dispatch for October 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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