May 7, 2021 2021-0932 Washington Dispatch for April 2021 The latest edition of Ernst & Young'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 - US Treasury releases President’s plan to overhaul corporate tax system
- Senators Wyden, Brown and Warner release International Tax Framework
- President Biden lays out $1.8 trillion American Families Plan proposal
- Senate Finance Committee chairman reintroduces clean energy legislation
Digital Taxation - Treasury Secretary proffers BEPS 2.0 Pillar One proposal to Inclusive Framework
IRS news - IRS issues proposed regs to coordinate WHT and gain deferral for certain foreign persons and partnerships investing in QOFs, clarify working capital safe harbor
- IRS releases FAQs on ICAP program for US multinational enterprises
- IRS extends time for submitting APA and MAP requests with e-signatures
OECD developments - OECD releases consultation document with proposed changes to Commentaries to OECD Model Tax Convention on Article 9 (Associated Enterprises) and related articles
- OECD publishes Arbitration Profiles for 30 countries under MLI, clarifies entry into effect
- OECD releases fourth batch of Stage 2 peer review reports on dispute resolution
- OECD releases third annual peer review report and revised peer review documents on BEPS Action 6 relating to prevention of treaty abuse
United Nations - UN tax committee approves new digital taxation article for UN model tax treaty
- UN releases new Transfer Pricing Manual
——————————————— ATTACHMENT Washington Dispatch for April 2021
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