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US Guidance Update: Pillar Two and more

Cross-border Tax Talks

CHAPTER

Navigating Covered Inbound Transactions and Potential Traps for Companies

This chapter examines the liquidation of holding companies and inbound reorganizations within the context of pillar two regulations. It explores the nuances and challenges companies encounter when eliminating unnecessary holding companies, stressing the complexities and restrictions involved in seeking relief under the guidelines.

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