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April 10, 2022
2022-0578

U.S. International Tax This Week for April 8

Ernst & Young's U.S. Tax This Week newsletter for the week ending April 8 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.

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Spotlight

There continues to be speculation in Washington about a post-Build Back Better Act reconciliation bill, with some Senators suggesting a package would need to come together by Memorial Day. Among the complicating factors are differences between Senator Joe Manchin's and Senator Kyrsten Sinema's tax positions — or if the Senators, in fact, want an agreement. It is also unclear the degree to which the White House will get more involved in moving a smaller budget reconciliation bill through Congress. Congress will be out of session for the next two weeks.

Senate Finance Committee Chairman Ron Wyden and committee member Rob Portman on 7 April introduced bipartisan legislation that would eliminate US foreign tax credits on taxes paid by companies in Russia and Belarus, as well as disallow other tax benefits. In a statement released on the same day, the Senators wrote: "If companies choose to keep doing business in Russia and paying taxes to Putin's government in the face of these atrocities, they should forfeit their foreign tax credits and deductions for taxes paid to Russia in the United States."

In another sign of deteriorating relations with Russia, the press is reporting that Treasury officially suspended the exchange of tax information with the Russian government "to bring additional pressure to bear on Russia." Treasury reportedly ceased exchanging tax information on 24 February.

The Organisation for Economic Co-operation and Development (OECD) on 4 April announced it will begin a public consultation on Draft Model Rules for Domestic Legislation on Scope under Amount A of BEPS 2.0 Pillar One. According to the OECD, "the purpose of the scope rules is to determine whether a Group will be in scope of Amount A." Written comments may be sent no later than 18 April.

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EY Guides, Surveys, and Reports

Asean Mobility Spotlight (April 2022)
Following multiple waves of COVID-19 outbreaks in 2020 and 2021, jurisdictions in Southeast Asia have finally found their footing amid accelerated vaccination rates and are reopening their borders and relaxing entry and quarantine requirements. These steps are expected to boost international business travel and tourism, both key elements of Southeast Asian economies which have been almost non-existent over the last two years and help to drive overall economic growth.

In this edition of the Asean Mobility Spotlight, we highlight the measures introduced by governments in Indonesia, Malaysia, Philippines, Singapore, Thailand and Vietnam, to support businesses and employees through the pandemic and beyond.

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Upcoming Webcasts

BEPS 2.0: Perspectives, practicalities and preparedness (April 12)
As countries deliberate and start to decide on how to implement the GloBE rules, what will this reality look like in practice and how (and when) should businesses prepare? During this EY Webcast, Ernst & Young professionals will discuss the implications of the latest developments and share perspectives on how businesses and administrations around the world are responding.

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Recent Tax Alerts

United States

— Apr 01: USCIS announces new actions to reduce backlogs and expand premium processing (Tax Alert 2022-0526)

Asia

— Apr 06: Indian Fiscal Budget 2022 includes key tax proposals for individuals (Tax Alert 2022-0557)

— Apr 06: Singapore's 2022 Budget Statement includes increase in top marginal personal income tax rates and updates to foreign workforce policies (Tax Alert 2022-0554)

— Apr 05: Japan enacts 2022 tax reform bill (Tax Alert 2022-0542)

Canada & Latin America

— Apr 07: EY Canada's Tax Matters @ EY for April 2022 (Tax Alert 2022-0571)

— Apr 06: Brazil removes pre-travel COVID-19 test requirement for vaccinated travelers (Tax Alert 2022-0562)

— Apr 06: Brazil modifies additional freight for merchant marine renewal rate (Tax Alert 2022-0560)

— Apr 05: Ontario increases nonresident speculation tax rate and extends application provincewide (Tax Alert 2022-0546)

— Apr 01: Peru's President amends rules for determining the fair market value of Peruvian shares in direct transfers (Tax Alert 2022-0532)

— Apr 01: Peru's President amends silent partnership rules (Tax Alert 2022-0530)

— Apr 01: Colombia modifies regulations on ultimate beneficial owners (Tax Alert 2022-0523)

— Apr 01: Canada expands sanctions on Russia, announces prohibitions on exports of goods and technology (Tax Alert 2022-0520)

Europe

— Apr 07: Cypriot Tax Department publishes MDR FAQs (Tax Alert 2022-0567)

— Apr 06: EU Finance Ministers continue negotiations to adopt Pillar Two Directive in light of Poland’s remaining objection (Tax Alert 2022-0558)

— Apr 06: UK Parliamentary committee calls for development of UK Carbon Border policy (Tax Alert 2022-0551)

— Apr 05: Swedish Parliament to vote on new work permit legislation on April 20 (Tax Alert 2022-0547)

— Apr 04: Italy publishes draft IVASS Regulation regarding online comparison system between insurance undertakings operating in Italy in the motor liability insurance sector (Tax Alert 2022-0536)

— Apr 01: Italy to introduce new rules for remote workers (Tax Alert 2022-0524)

Multinational

— Apr 04: OECD releases fourth annual peer review report on BEPS Action 6 relating to prevention of treaty abuse (Tax Alert 2022-0538)

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2022-15Internal Revenue Bulletin of April 11, 2022

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Additional Resources

Ernst & Young Client Portal, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

— EY/Passport. EY/Passport is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

Because the matters covered herein are complicated, U.S. International 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.

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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