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Navigating Complexities of US Corporate Tax Laws and OECD Guidance
This chapter explores the intricate details of the US Corporate Alternative Minimum Tax (CAMT), the technicalities of the Camp T tax for foreign multinational groups, and the challenges faced by taxpayers in complying with pillar two rules and local corporate income tax. It also discusses the concerns around potential double counting of income in the KMT tax base and the complexities of tax rules regarding dividends and distributions to US shareholders and CFCs, emphasizing compliance challenges for large US multinationals.