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February 4, 2022

Washington Dispatch for January 2022

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:


  • Biden Administration looks to scaled- back Build Back Better legislation IRS news

Treasury and IRS news

  • Final regulations treat domestic partnerships as aggregates for applying certain subpart F provisions, and proposed regulations would apply a similar approach to PFICs
  • IRS changes to instructions for 2021 partnership Schedules K-2 and K-3 relevant to many partnerships, including private equity and private capital funds
  • IRS announces pilot fast-track program to resolve corporate letter ruling requests in 12 weeks

OECD Developments

  • BEPS 2.0 model rules commentary expected to be released soon
  • OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework
  • OECD publishes 2022 Transfer Pricing Guidelines
  • OECD releases eighth batch of Stage 2 peer review reports on dispute resolution


Washington Dispatch for January 2022