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Threading the Needle: Pillar Two and the IRA’s Green Energy Credits
Cross-border Tax Talks
The Model Rules for Refundable Tax Credits
High-refundable credits were credits as defined under the model rules that had to be payable in cash within four years if a taxpayer did not have sufficient tax liability against which to use the credit. If a credit satisfies that qualified refundable credit criteria, it is treated as the equivalent of a government grant. And so what that means is if you receive $10 of a nonrefundable, this residual category of credit, that goes directly into the numerator of your ETR potentially dropping you below 15%.
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