AI-powered
podcast player
Listen to all your favourite podcasts with AI-powered features
1min snip
US Guidance Update: Pillar Two and more
Cross-border Tax Talks
Avoiding Double Counting in International Taxation
The biggest international tax issue with KMT was the potential double counting of income in the tax base in AFSI. This issue arose from two separate rules applied to a single CFC's earnings: the pass-through flow-through rule that taxes a US shareholder on its pro-rata share of the net income of the CFC, and the rule that requires including dividends from non-consolidated group corporations in AFSI. The concern was that the same earnings could be taxed first at the CFC level and then again when distributed, leading to double counting.
00:00
Transcript
Episode notes
Get the Snipd
podcast app
Unlock the knowledge in podcasts with the podcast player of the future.
AI-powered
Discover
highlights
Listen to the best highlights from the podcasts you love and dive into the full episode
Save any
moment
Hear something you like? Tap your headphones to save it with AI-generated key takeaways
Share
& Export
Send highlights to Twitter, WhatsApp or export them to Notion, Readwise & more
AI-powered
podcast player
Listen to all your favourite podcasts with AI-powered features
Discover
highlights
Listen to the best highlights from the podcasts you love and dive into the full episode