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Searching for Pillar Two clarity: The OECD’s Administrative Guidance

Cross-border Tax Talks

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The Administrative Guidance on Blended CFC Regimes

The only tax regime that would seem to meet the definition and categories needed is guilty. It effectively requires no domestic inclusion of income, so for US taxpayers, camped or book minimum tax will not be included. And I'm not aware of any other jurisdiction Exactly. So we've asked a similar type of agreement.

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