Pillar Two Admin Guidance Glimpses of clarity
Cross-border Tax Talks
Complex Rules on Entity Classification and Allocation of Taxes in Cross-Border Structures
The chapter delves into the nuanced regulations on entity classification and tax allocation for cross-border structures, including key points on tax transparent entities, reverse hybrid entities, and the impact on US multinationals and fund structures. It also addresses future expectations for administrative guidance and potential delays due to political factors, while touching upon specific topics like anti-arbitrage and the globe reorg rule.
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