US Guidance Update: Pillar Two and more
Cross-border Tax Talks
Complex Tax Issues and the Importance of Basis Credit
The discussion revolves around the complexity of determining foreign use in the context of DCL points, with firms debating the subject based on safe harbor rules. The speaker emphasizes the need for clear guidance from OECD or the US government. The conversation then shifts to Notice 2024-16 regarding Previously Taxed Earnings and Profits (PTAAP), highlighting the importance of basis credit in CFC regimes where income is taxed at the US shareholder level to avoid double taxation on distributed income that has already been taxed.
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