Notice 2021-28, 2021-2022 Priority Guidance Plan Submission

87 Pages Posted: 14 May 2021

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

Date Written: May 11, 2021


This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.

Much of the submission concerns sourcing and effectively connected income rules. It also covers the existence of unanticipated partnerships among an MNC's group members that conduct joint business activities. Regarding subpart F, it makes suggestions concerning the manufacturing branch rule. Finally, it includes suggestions regarding the manner in which tax treaties should or should not apply to certain hybrid entities.

Keywords: ECI, Effectively Connected Income, Tax Treaties, Source of Income, Transfer Pricing, §482, Partnership, Check-the-Box, Entity Classification Rules, Subpart F, Branch Rule

JEL Classification: H21, H25, K34, E62

Suggested Citation

Kadet, Jeffery M., Notice 2021-28, 2021-2022 Priority Guidance Plan Submission (May 11, 2021). Available at SSRN: or

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

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