Threading the Needle: Pillar Two and the IRA’s Green Energy Credits
Cross-border Tax Talks
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The Impact of the Income Inclusion Rule on US Taxes
The US statutory rate of 21 at a few points for state taxes that the R&D credit because it is not a qualified refundable tax credit. It reduces the numerator and it can cause a US taxpayer to fall below the 15% for globe purposes. The benefit of those R&D credits goes to some non US government whether that's through the IIR if it's a sub of a non US parent or the UTPR.
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