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US Treasury provides guidance on the creditability of Pillar Two taxes, grants relief for pre-GloBE DCLs and extends temporary relief from FTC regulations

|Tax Alerts, Legislation & Policy, Na ...|United States
United States

  • The Notice indicates that a QDMTT is generally creditable, whereas an IIR may or may not be creditable depending on whether the taxpayer's US federal income tax liability may be included in its computation.
  • The Notice provides that the GloBE Rules will not cause the foreign use of a DCL incurred in a pre-GloBE tax year, subject to an anti-abuse provision.
  • The Notice extends the relief period from th…

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