U.S. International Tax This Week for April 22

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April 24, 2022
2022-0662

Ernst & Young's U.S. Tax This Week newsletter for the week ending April 22 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

Congress returns next week from its spring recess amid speculation that Democrats may make one last attempt to pass pared-down budget reconciliation legislation before the August recess. There are mixed signals 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 Senators Kyrsten Sinema's and Joe Manchin's tax positions — Senator Sinema opposes tax rate increases — and uncertainty over whether both Senators Manchin and Sinema want an agreement.

A senior Treasury official this week said the Biden Administration views both the Treasury Greenbook's repeal of the base erosion and anti-abuse tax (BEAT) and replacement with an undertaxed profits rule (UTPR) and the House-passed Build Back Better Act's (HR 5376) BEAT corrections as furthering the OECD's BEPS 2.0 Pillar Two global minimum tax proposal. The official was quoted as saying the Administration "fully supports the BEAT reforms in the House-passed bill." According to the official: "Both the green book UTPR proposal and the House BEAT reforms would create powerful incentives for other countries to join and comply with the new global regime, and both further the goals of it."

The Treasury official also confirmed the Administration remains confident that Congress will pass international tax reform and that the US will meet its commitment to reform the global intangible low-taxed income (GILTI) and BEAT "which remains a top priority for the Administration."

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Upcoming Webcasts

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During this EY Webcast, Ernst & Young professionals will explore the results of the newly released EY 2022 Work Reimagined Survey, which included more than 17,000 employees and 1,500 employers across 22 countries.

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Recent Tax Alerts

Africa

— Apr 21: Mauritius amends income tax regulations regarding 80% income exemption for investment dealers and defining specialized software and systems (Tax Alert 2022-0657)

Canada & Latin America

— Apr 21: Government of Canada to repeal the 'Certain Goods Remission Order' (COVID-19) (Tax Alert 2022-0655)

— Apr 18: Peru's President amends VAT Law and Tax Code (Tax Alert 2022-0635)

— Apr 18: Argentina relaxes COVID-19-related entry requirements (Tax Alert 2022-0634)

— Apr 18: Costa Rica's Ministry of Economy, Industry and Commerce imposes additional ad valorem duty on sugar imports from Colombia (Tax Alert 2022-0633)

Europe

— Apr 20: UK Tax Authority issues further guidance on UK Plastic Packaging Tax (Tax Alert 2022-0649)

Middle East

— Apr 20: Turkey enacts new tax law (Tax Alert 2022-0653)

— Apr 20: Turkey increases special consumption tax base for portable radiotelephone devices (Tax Alert 2022-0645)

Multinational

— Apr 20: OECD releases ninth batch of Stage 2 peer review reports on dispute resolution (Tax Alert 2022-0650)

— Apr 20: The Latest on BEPS and Beyond for April 2022 (Tax Alert 2022-0644)

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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.