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November 9, 2021

Washington Dispatch for October 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:


  • President Biden releases pared down budget reconciliation framework

Digital economy

  • G20 leaders confirm commitment to global tax changes under BEPS 2.0
  • Six country Joint Statement on transitional approach to existing unilateral measures during period before Pillar One is in effect

Treasury and IRS news

  • IRS rules gains and losses arising from commodity hedges may be sourced by reference to the underlying hedged inventory property
  • IRS revises Forms W-8ECI, W-8BEN-E, W-8BEN
  • FinCEN provides FBAR relief to victims of recent natural disasters giving them until 31 December 2021 to file

Transfer pricing news

  • IRS maintaining policy on 'telescoping' in APA and MAP cases while trying to alleviate administrative burden, official says
  • Cyprus clarifies US-Cyprus CAA for exchange of CbC reports

OECD developments

  • MLI Conference of the Parties issues two opinions re MAP implementation and entry into effect of arbitration rules
  • OECD releases outcomes of fourth phase of peer reviews on BEPS Action 13
  • OECD releases seventh batch of Stage 2 peer review reports on dispute resolution
  • OECD releases PRC Stage 2 peer review report on implementation of Action 14 minimum standard

United Nations

  • UN releases MAP and Tax Dispute Resolution Handbook


Washington Dispatch for October 2021