October 8, 2021 2021-1836 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: Legislation - 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
——————————————— ATTACHMENT Washington Dispatch for September 2021 
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