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

Cross-border Tax Talks

CHAPTER

The Discomfort of Converting US R&D Credit to Refundable Credit

There are credits in the US system that are what we use the terminology direct pay but it's essentially I would say economically equivalent to just a refundable credit. So as a technical matter you know you and I can scratch it out in the next 30 minutes to turn the US R&D credit into a refundability credit. The reality is there are significant revenue implications to that and there are significant policy implications so on the revenue side again I mentioned the R&DCredit is I believe the largest of our general business credits if you turn it into a refundablecredit you would significantly increase the revenue cost to the US government for doing that. Congress will have to take on board obviously in an environment

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