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August 31, 2023

U.S. International Tax This Week for August 31

Ernst & Young's U.S. International Tax This Week newsletter for the week ending August 31 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.


House Ways and Means Committee Chairman Jason Smith (R-MO) shortly will lead a delegation of committee members to OECD headquarters in Paris to discuss the BEPS 2.0 project. The trip, originally planned for earlier this summer but postponed, reportedly is meant to express congressional concerns to the OECD and European officials regarding various aspects of the BEPS 2.0 project. Although the delegation has not disclosed what will be on the meeting agenda, bipartisan congressional tax leaders have pointed to the Pillar Two Under Taxed Profits Rule (UTPR) as particularly problematic. Chairman Smith and other congressional tax leaders have indicated that Congress will have final say on any BEPS agreement to which the US is a party.

The Ways and Means Committee held a hearing in July at which members expressed growing frustration with how the Biden Administration has handled the BEPS negotiations. The OECD later in July issued several technical documents, including one that floated a transitional UTPR safe harbor, among other proposals.

A senior OECD official this week was quoted as saying that it is “certainly possible and likely” that there will be simplifications made to how companies file global minimum tax information used to determine minimum tax liabilities. The GloBE Information Return was finalized this summer and includes a transitional framework for simplified reporting on a jurisdictional, rather than entity, basis, in addition to specifying how the information is to be shared among jurisdictions that implement the GloBE Rules.

The United Nations (UN) this week released a final report suggesting alternative options to promote international tax cooperation. The report offers an analysis of the existing arrangements in international cooperation and provides other options to “make such cooperation fully inclusive and more effective and outlines potential next steps.” According to the report, enhancing the UN’s role “in tax-norm shaping and rule-setting, with full consideration of existing multilateral and international arrangements, appears the most viable path for making international tax cooperation fully inclusive and more effective.” As in an earlier released draft, the final report identifies three options to be considered, including a tax multilateral convention, a framework convention on international tax cooperation, and a framework for international tax cooperation.

A Senate Finance Committee aide this week confirmed that a hearing on the Biden Administration’s nomination of Marjorie Rollinson to be the next IRS Chief Counsel will be on the committee’s agenda when the Senate returns from the August recess. Rollinson, a former IRS Associate Chief Counsel (International) was EY’s Deputy Director of National Tax among other senior EY positions. No date for a hearing has yet been set.

Upcoming Webcasts

International tax talk quarterly series with the EY Global Tax Desk Network (September 12)
Recent proposed tax changes across the globe may have significant implications for companies in the next quarter and beyond. Some of these changes are complex, so it is important that businesses understand them and try to prepare now – particularly for those that take effect in 2024. Please join our EY webcast for insights on recent developments in Australia, Brazil, Hong Kong, Mexico, Switzerland, and the United States and an analysis of how they might affect your businesses.

Tax in a time of transition: legislative, economic, regulatory and IRS developments (September 15)
Companies need to keep pace with a tax and economic environment in transition. This requires understanding tax policy trends and anticipating future developments that could impact their operations. Join us for a fast-paced overview of recent tax and economic developments designed to help you stay on top of changes in today's shifting economic, legislative and regulatory environment. In this regularly occurring EY webcast series, panelists will provide updates on: (i) The US economy and tax policy; (ii) What's happening at the IRS; (iii) Breaking developments.

Recent Tax Alerts


— Aug 29: China Mainland eliminates pre-travel COVID-19 test requirement (Tax Alert 2023-1459)

— Aug 28: Nepal Inland Revenue Department amends VAT and DST procedures relating to digital service (Tax Alert 2023-1454)

Canada & Latin America

— Aug 29: Brazil's visa requirement for nationals of Australia, Canada and the United States postponed to January 2024 (Tax Alert 2023-1460)

— Aug 28: Canada's Global Minimum Tax Act released for public comment (Tax Alert 2023-1456)


— Aug 28: Italy's Enabling Law 2023 makes VAT changes (Tax Alert 2023-1455)

— Aug 25: Italy approves framework for major tax reform, including BEPS Pillar Two principles (Tax Alert 2023-1451)

IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2023-36Internal Revenue Bulletin of September 5, 2023

Additional Resources

EY’s Tax News Update, 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’s Tax and Law Guides. Tax and Law Guides | EY - Global 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.