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September 22, 2023

Report on recent US international tax developments - 22 September 2023

US budget negotiations are continuing as House Republicans look for agreement on a continuing resolution (CR) to fund the federal government past the 30 September deadline that can garner enough votes to pass the chamber. Assuming passage of a CR in the House, the bill would still require Senate approval and the President's signature to avoid a government shutdown.

The tax press reported this week that House Republican tax lawmakers want countries to delay their implementation of BEPS Pillar Two, while also urging nations to adopt rules similar to the US Global Intangible Low-taxed income (GILTI) regime. According to the report, the focus has moved from the OECD to getting countries on board to adopt something akin to GILTI.

A House Ways and Means Committee delegation recently traveled to Europe to explain to OECD and European officials Congress's concerns regarding the BEPS 2.0 project. Among other things, Ways and Means Chairman Jason Smith (R-MO) delivered the message that the US already has a global minimum tax in the GILTI regime and does "not object to others implementing their own GILTI-type taxes." The Chairman also reportedly warned that the US "will not suddenly repeal our proven system in favor of an untested regime with substantial complexity and uncertainty."

In the Senate, the Finance Committee announced a hearing for 28 September to consider nominations, including that of Marjorie Rollinson to be the next IRS Chief Counsel. Rollinson spent most of her career at EY, retiring as EY Deputy Director of National Tax, and has held several senior positions at the IRS, including Associate Chief Counsel (International).


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


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