Following the work of the OECD/G20 Inclusive Framework and the release of its Pillar II administrative guidance, Wardell-Burrus considers this administrative guidance specifically as it relates to the GILTI regime as a CFC tax Regime; the QDMTT which applies before CFC taxes; and the new allocation mechanism of GILTI as a blended CFC Tax. He concludes that the fact that the QDMTT applies before CFC Regimes means that there can be a competitive downside to adopting a QDMTT.
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