04 February 2022

Washington Dispatch for January 2022

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:

Legislation

Biden Administration looks to scaled-back Build Back Better legislation

IRS news

Final regulations treat domestic partnerships as aggregates for applying certain subpart F provisions, and proposed regulations would apply a similar approach to PFICs

  • IRS changes to instructions for 2021 partnership Schedules K-2 and K-3 relevant to many partnerships, including private equity and private capital funds

  • IRS announces pilot fast-track program to resolve corporate letter ruling requests in 12 weeks

    OECD news

    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

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    ATTACHMENT

    Washington Dispatch for January 2022

    Document ID: 2022-5142