NYSBA Tax Section Focuses on U.S. Tax Implications of OECD Reform
NYSBA Tax Section Focuses on U.S. Tax Implications of OECD Reform
- AuthorsCassanos, Robert
- Institutional AuthorsNew York State Bar Association Tax Section
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2022-23799
- Tax Analysts Electronic Citation2022 TNTI 140-232022 TNTG 140-232022 TNTF 140-21
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)
- AuthorsCassanos, Robert
- Institutional AuthorsNew York State Bar Association Tax Section
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2022-23799
- Tax Analysts Electronic Citation2022 TNTI 140-232022 TNTG 140-232022 TNTF 140-21