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Threading the Needle: Pillar Two and the IRA’s Green Energy Credits

Cross-border Tax Talks

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The Administrative Guidance on Equity Investments

The original model rules made clause, I should say this, essentially had a rule that said investments that you account for under the equity method get kicked out of the pillar two base. The administrative guidance starts out by saying, not so fast, what we're going to tell you is these credits that flow through these equity method structures. You have to take them through your ETR for pillar two purposes unless they qualify for qualified flow through tax benefits. Once you get to your 101st dollar, now it's treated just like any other non-refundable credit, it reduces your ETR. And my understanding for our listeners that are under IFRS, that there are similar type of policies that

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