Report on recent US international tax developments – 14 January 2022

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EY Global

14 Jan 2022
Subject Tax Alert
Categories Corporate Tax
Jurisdictions United States

There was no substantive action on President Joe Biden’s proposed Build Back Better legislation this week as Congressional Democrats pivoted to other legislative priorities, primarily voting rights and the filibuster. The main question regarding the future of the Build Back Better Act (BBBA) has been whether President Biden and Democratic leaders in Congress could accept Senator Joe Manchin’s pre-holiday offer to the White House for 10-year funding on climate, health, and universal pre-kindergarten, but not extension of the now-expired expanded Child Tax Credit. The press is now reporting that Senator Manchin no longer supports his US$1.8 trillion BBBA counterproposal that he made to President Biden in December. Senator Manchin also is said to have signaled that he no longer would favor any legislation resembling President Biden’s expansive Build Back Better plan, although the Senator indicated there are individual proposals that he would support.

White House Press Secretary Jen Psaki said on 10 January, “… conversations are continuing behind the scenes at a staff level. And I can assure you that… that the President is going to continue to press to get Build Back Better done … .”

A Treasury official this week said that the Government is developing interim guidance on cryptocurrency reporting, but provisions included in the recently enacted infrastructure bill have required officials to make revisions to drafts. The official was quoted as saying that regulations covering reporting requirements under Internal Revenue Code Section 6045 are a priority, but declined to provide a timeline for the regulations.

An Internal Revenue Service (IRS) official this week also was quoted as saying that the IRS Office of Fraud Enforcement (OFE) is working with the IRS Criminal Investigation division to ensure that agents have the necessary technology and training to find and follow cryptocurrency transactions. According to the official, the Government will analyze available information by focusing on cryptocurrency transactions and taxpayers’ financial and tax filings.


For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC
  • Arlene Fitzpatrick
  • Joshua Ruland

For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.