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US Guidance Update: Pillar Two and more

Cross-border Tax Talks

NOTE

Thorough Review of Recent Tax Notices

Three important notices were issued: first, the deferment of the final 2021-2022 foreign tax credit regulations due to multiple revisions to tailor the regulations to avoid covering irrelevant taxes; second, the release of foreign tax credit guidance on the credibility of certain taxes under Pillar 2; third, guidance on the interaction of the domestic dual consolidated loss with Pillar 2.

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