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NYSBA Tax Section Focuses on U.S. Tax Implications of OECD Reform

JUL. 21, 2022

NYSBA Tax Section Focuses on U.S. Tax Implications of OECD Reform

DATED JUL. 21, 2022
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[Editor's Note:

View the full text of the report, including appendices, in the PDF version of the document.

]

July 21, 2022

The Honorable Lily Batchelder
Assistant Secretary (Tax Policy)
Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

The Honorable Charles P. Rettig
Commissioner
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

The Honorable William M. Paul
Principal Deputy Chief Counsel and Deputy Chief Counsel (Technical)
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Re: Report No. 1465-Report on the OECD Global Anti-Base Erosion Model Rules (Pillar Two).

Dear Ms. Batchelder and Messrs. Rettig and Paul:

I am pleased to submit Report No. 1465 of the Tax Section of the New York State Bar Association discussing certain of the U.S. federal income tax implications of the Model Rules under Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting.

We appreciate your consideration of our Report. If you have any questions, please feel free to contact us and we would be happy to assist.

Respectfully Submitted,

Robert Cassanos
Chair

Enclosure

cc:
Peter H. Blessing
Associate Chief Counsel (International)
Internal Revenue Service

Itai Grinberg
Deputy Assistant Secretary (Multilateral Negotiations)
Department of the Treasury

Lindsay Kitzinger
Deputy International Tax Counsel
Department of the Treasury

Mae J. Lew
Deputy Associate Chief Counsel (International)
Internal Revenue Service

John Merrick
Senior Level Counsel
Internal Revenue Service

Jose Murillo
Deputy Assistant Secretary International Affairs
Department of the Treasury

Erika Nijenhuis
Senior Counsel
Department of the Treasury (Office of Tax Policy)

Michael Plowgian
Counselor
Department of the Treasury

Carol B. Tan
Special Counsel (International)
Internal Revenue Service

Isaac Wood
Attorney-Advisor
Department of the Treasury (Office of Tax Policy)

Brenda Zent
Special Advisor
Department of the Treasury (Office of Tax Policy)

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