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Why should someone make a career in international tax?
Doug and Wade start the technical discussion with recent guidance on the Foreign Tax Credit Rules, Notice 2023-80, which really is three IRS notices in one.
Wade and Doug discuss guidance on the application of foreign tax credits for Pillar Two and Treasury’s views on the issue with respect to the creditability of the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and the Qualified Domestic Minimum Top-up Tax (QDMTT)
The Section 78 gross-up: How the rules work; the issue with circularity
Treasury's views on the QDMTT rules in certain jurisdictions, both for ordering purposes and requirements for creditability
The interaction of the dual consolidated losses (DCLs) and Pillar Two; what are the DCL rules?
Challenges under the interaction of US rules and OECD rules
Notice 2024-16 on Previously Taxed E&P (PTEP); what is PTEP, to which kinds of transactions does it apply (e.g., covered inbound transactions), and how might the guidance apply more narrowly
Taxpayers should consider commenting while the period is still open
Wade and Doug discuss the possible timing of proposed regulations
Overview of the corporate alternative minimum tax (CAMT), including basic mechanics
How does CAMT interact with Pillar Two?
Overview of CAMT Notice 2023-64; how to deal with CAMT FTCs
How are distributions of CFC earnings treated under Notice 2024-10?
What exceptions under CFC distributions do taxpayers need to be aware of?
What was not covered in the notice? What's been addressed in comment letters?
Other guidance we should expect from Treasury in 2024, including CAMT, possible rules on cloud computing, and the sourcing of transactions, domestically controlled REITS, PFICs and the aggregate treatment of partnerships, and more FTC guidance.