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

August 31, 2023

Report on recent US international tax developments 31 August 2023

US House Ways and Means Committee Chairman Jason Smith (R-MO) shortly will lead a delegation of committee members to OECD headquarters in Paris to discuss the BEPS 2.0 project. The trip, originally planned for earlier this summer but postponed, reportedly is meant to express congressional concerns to the OECD and European officials regarding various aspects of the BEPS 2.0 project. Although the delegation has not disclosed what will be on the meeting agenda, bipartisan congressional tax leaders have pointed to the Pillar Two Under Taxed Profits Rule (UTPR) as particularly problematic. Chairman Smith and other congressional tax leaders have indicated that Congress will have final say on any BEPS agreement to which the US is a party.

The Ways and Means Committee held a hearing in July at which members expressed growing frustration with how the Biden Administration has handled the BEPS negotiations. The OECD later in July issued several technical documents, including one that floated a transitional UTPR safe harbor, among other proposals.

A senior OECD official this week was quoted as saying that it is "certainly possible and likely" that there will be simplifications made to how companies file global minimum tax information used to determine minimum tax liabilities. The GloBE Information Return was finalized this summer and includes a transitional framework for simplified reporting on a jurisdictional, rather than entity, basis, in addition to specifying how the information is to be shared among jurisdictions that implement the GloBE Rules.

The United Nations (UN) this week released a final report suggesting alternative options to promote international tax cooperation. The report offers an analysis of the existing arrangements in international cooperation and provides other options to "make such cooperation fully inclusive and more effective and outlines potential next steps." According to the report, enhancing the UN's role "in tax-norm shaping and rule-setting, with full consideration of existing multilateral and international arrangements, appears the most viable path for making international tax cooperation fully inclusive and more effective." As in an earlier released draft, the final report identifies three options to be considered, including a tax multilateral convention, a framework convention on international tax cooperation, and a framework for international tax cooperation.

A Senate Finance Committee aide this week confirmed that a hearing on the Biden Administration's nomination of Marjorie Rollinson to be the next IRS Chief Counsel will be on the committee's agenda when the Senate returns from the August recess. Rollinson, a former IRS Associate Chief Counsel (International) was EY's Deputy Director of National Tax among other senior EY positions. No date for a hearing has yet been set.


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

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

Published by NTD's Tax Technical Knowledge Services group; Carolyn Wright, legal editor


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