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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 OECD's Administrative Guidance on Transferable Credits

The story may not end here with the last administrative guidance, right? But we'll keep our eye on the US Treasury for any reaction. And so to the extent people are hoping for a quick certain answer that transferable is the same as qualified refundable, I fear they're going to be waiting a long time. Doug McConney: We will bring you back for your eighth appearance to talk about Pillar 2.

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