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March 27, 2022

U.S. Tax This Week for March 25

Ernst & Young's U.S. Tax This Week newsletter for the week ending March 25 is now available. Prepared by Ernst & Young's National Tax Department in Washington, D.C., this weekly update summarizes important news, cases, and other developments in U.S. taxation.

Top of the Week

OECD releases Commentary and illustrative examples on Pillar Two Model Rules

On 14 March 2022, the Organisation for Economic Co-operation and Development (OECD) released the Commentary to the Pillar Two Model Rules (the Commentary) as agreed by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). The Pillar Two Model Rules,1 released on 20 December 2021, define the scope and key mechanics for the Pillar Two system of global minimum tax rules, which includes the Income Inclusion Rule (IIR) and the Under Taxed Payments Rule (UTPR), referred to collectively as the "GloBE rules." EY Tax Alert 2022-0458 has details.

Federal lawmakers propose extending the waiver of state interest charges on federal UI loans

U.S. Senate Majority Whip Dick Durbin and U.S. Representative Danny K. Davis (D-IL) announced that they and other U.S. senators and representatives have introduced legislation that would extend the period that states are not charged for interest on their federal unemployment insurance (UI) loans. EY Tax Alert 2022-0476 has details.

Upcoming Webcasts

17th Annual International Tax Quantitative and Reporting Conference (March 28 & 29)
The 17th Annual International Tax Quantitative and Reporting Conference will continue to explore in detail the considerations associated with international tax reporting and quantitative analysis related to today’s ever-changing environment, including US legislative developments, international initiatives and regulatory changes. Key topics will include the recently released foreign tax credit regulations, BEPS, the Build Back Better Act (and potential subsequent legislation) and significant changes to US international reporting requirements for 2021 tax years. Register.

BorderCrossings . . . With EY transfer pricing and tax professionals (March 31)
During this EY Webcast, Ernst & Young professionals will examine some of the transfer pricing considerations presented by group captive finance companies.

Tax in the time of COVID-19: Update on legislative, economic, regulatory and IRS developments (April 1)
During this EY Webcast, Ernst & Young professionals will discuss how businesses can navigate the tax policy environment and continue to effectively operate their tax function in this time of crisis and change. Panelists will provide updates on: (i) the US economy and tax policy; (ii) breaking developments; and (iii) what’s happening at the IRS.

US corporate income tax compliance - Tax year 2021 readiness and preparing your tax function for what’s next (April 6)
During this EY Webcast, Ernst & Young professionals will discuss preparing for the 2021 US federal and state tax filings as well as key considerations for international filers.

What key trends are shaping the future of cross-border controversy (April 7)
During this EY Webcast, Ernst & Young professionals will address various cross-border controversy topics and feature insights from EY professionals from around the globe.

Recent Tax Alerts

Internal Revenue Service

— Mar 22: IRS rules payments to REIT for waiver of liability shield for property damage are rents from real property (Tax Alert 2022-0460)

— Mar 21: IRS again rules that normalization rules do not apply to cost of removal (Tax Alert 2022-0456)

— Mar 18: IRS TE/GE publishes three new Technical Guides on self-dealing taxes, taxable expenditure excise taxes and religious entities (Tax Alert 2022-0451)

— Mar 18: IRS concludes an accountable care organization does not qualify for IRC Section 501(c)(4) status (Tax Alert 2022-0450)


— Mar 24: Québec budget 2022-23 discussed (Tax Alert 2022-0475)

— Mar 24: Saskatchewan budget 2022-23 discussed (Tax Alert 2022-0473)

— Mar 24: Turkey’s TP documentation requirement deadlines are approaching (Tax Alert 2022-0472)

— Mar 24: Kenya considers legal right for remote workers to ‘disconnect’ and establish specific working hours (Tax Alert 2022-0466)

— Mar 23: Uncertainty remains on whether tax authority will recognize tax basis of Peruvian shares acquired indirectly from January 2012 through March 2022 (Tax Alert 2022-0470)

— Mar 23: Canada implements changes to the British Columbia Provincial Nominee Program (Tax Alert 2022-0469)

— Mar 23: Canada's special immigration measures for Ukrainians now accepting applications (Tax Alert 2022-0468)

— Mar 23: Canada to remove pre-entry test requirements for fully vaccinated travelers (Tax Alert 2022-0467)

— Mar 23: Highlights of Québec budget 2022-23 provided (Tax Alert 2022-0465)

— Mar 23: New Brunswick budget 2022-23 discussed (Tax Alert 2022-0464)

— Mar 23: Hong Kong proposes family office tax concession regime (Tax Alert 2022-0463)

— Mar 21: OECD releases Commentary and illustrative examples on Pillar Two Model Rules (Tax Alert 2022-0458)

— Mar 22: Turkey’s General Directorate of Customs issues letter clarifying the Special Consumption Tax base (Tax Alert 2022-0457)


— Mar 25: What to expect in Washington (March 25) (Tax Alert 2022-0481)

— Mar 24: Health, Education, Labor & Pensions hearing on strengthening federal mental health and substance use disorder programs: Opportunities, challenges and emerging issues (Tax Alert 2022-0474)


— Mar 24: Federal lawmakers propose extending the waiver of state interest charges on federal UI loans (Tax Alert 2022-0476)

— Mar 23: Ohio Supreme Court clarifies 'true-object test' for bundled transactions and sales tax on automated services (Tax Alert 2022-0471)

— Mar 22: Oregon confirms state income tax rules for wages paid to remote workers (Tax Alert 2022-0461)

— Mar 21: California extends COVID-19 supplemental paid sick leave through September 30, 2022 (Tax Alert 2022-0459)

— Mar 21: Missouri Department of Revenue provides remote worker income tax guidance for employers and employees (Tax Alert 2022-0455)

IRS Weekly Wrap-Up


 REG-105954-20Required Minimum Distributions; Correction
 26 CFR Part 1This rule is being published by the Office of the Federal Register to correct an editorial or technical error that appeared in the most recent an1nual revision of the Code of Federal Regulations; Correction.

Revenue Procedures

 2022-20Administrative, Procedural, and Miscellaneous

Revenue Rulings

 2022-07Section 6103.—Confidentiality and disclosure of returns and return information


 2022-06Temporary Suspension of IRS Prototype IRA Opinion Letter Program


 2022-14Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates

Internal Revenue Bulletin

 2022-13The Internal Revenue Bulletin 2022-13 will be posted on by COB Friday 03/25/2022.

Because the matters covered herein are complicated, U.S. Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.