On notice: US developments and Moore hype
Cross-border Tax Talks
Temporary Foreign Tax Credit Relief and Anticipated Guidance on Jurisdictional Nexus
This chapter discusses the temporary foreign tax credit relief introduced in Notice 2023-55, allowing taxpayers to apply old regulations for a limited period. It also explores the anticipated guidance on jurisdictional nexus and the credibility of qualified domestic minimum top-up taxes and conclusion rule taxes. The government plans to issue proposed regulations on the foreign tax credit by the end of the year, extending the transition relief and providing guidance on pillar two taxes.
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