U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework
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Confines of Covered Inbound Transactions Under Notice 2024-16
Notice 2024-16 announces the government’s intent to issue regs to provide an adjustment to a domestic acquiring corporation’s basis of acquired CFC stock for covered inbound transactions. Laura E. Williams, Jennifer Franceschini, and Raza Janjua of PwC explain how the narrow definition of covered inbound transactions and the limitations outlined in Notice 2024-16 may leave taxpayers exposed to double taxation in many situations, and argue that future regulations should provide for expanded relief.
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