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May 7, 2021

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:


  • 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


Washington Dispatch for April 2021