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

• 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

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ATTACHMENT

Washington Dispatch for January 2022