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October 8, 2021

Washington Dispatch for September 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:


  • Congress fails to pass infrastructure and budget reconciliation legislation
  • House Ways & Means Committee reports out reconciliation bill with major international tax proposals
  • Senate Finance Committee Chairman releases partnership tax proposals

Treasury and IRS news

  • Final foreign tax credit regulations will include jurisdictional nexus requirement, Treasury official says
  • IRS allows taxpayer to reverse GILTI “gap period” transaction through late CTB election
  • IRS articulates five-factor test in determining income inclusion of reimbursement payments
  • IRS issues final regulations on treatment of qualified improvement property and provides guidance on foreign tax credits
  • IRS seeing more billion-dollar MAP cases
  • IRS lists jurisdictions with US information exchange agreements that allow reporting of certain deposit interest

OECD Developments

  • G7 Finance Ministers make progress on BEPS 2.0 issues in lead-up to October 2021 meetings


Washington Dispatch for September 2021