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April 8, 2022
Report on recent US international tax developments – 8 April 2022
There continues to be speculation in Washington about a post-Build Back Better Act reconciliation bill, with some senators suggesting a package would need to come together by Memorial Day. Among the complicating factors are differences between Senators Joe Manchin’s and Kyrsten Sinema’s tax positions -- or, in fact, if the Senators want an agreement. It is also unclear the degree to which the White House will get more involved in moving a smaller budget reconciliation bill through the Congress. Congress will be out of session for the next two weeks.
Senate Finance Committee Chairman Ron Wyden and committee member Rob Portman on 7 April introduced bipartisan legislation that would eliminate United States (US) foreign tax credits on taxes paid by companies in Russia and Belarus, as well as disallow other tax benefits. In a statement released on the same day, the Senators wrote: “If companies choose to keep doing business in Russia and paying taxes to Putin’s government in the face of these atrocities, they should forfeit their foreign tax credits and deductions for taxes paid to Russia in the United States.”
In another sign of deteriorating relations with Russia, the press is reporting that the US Treasury officially suspended the exchange of tax information with the Russian Government “to bring additional pressure to bear on Russia.” Treasury reportedly ceased exchanging tax information on 24 February.
The Organisation for Economic Co-operation and Development (OECD) on 4 April announced it will begin a public consultation on Draft Model Rules for Domestic Legislation on Scope under Amount A of BEPS 2.0 Pillar One. According to the OECD, “the purpose of the scope rules is to determine whether a Group will be in scope of Amount A.” Written comments may be sent no later than 18 April 2022.
For additional information with respect to this Alert, please contact the following:
Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC