IRS’s Pillar Two, Foreign Tax Credit Guidance Present Conflicts
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IRS’s Pillar Two, Foreign Tax Credit Guidance Present Conflicts
Jeffrey Tebbs and Caroline Reaves of Miller & Chevalier Chartered analyze recent guidance addressing the interaction of the US foreign tax credit system with Pillar Two top-up taxes coming into effect in 2024. According to Tebbs and Reaves, it isn’t clear that Pillar Two taxes can (or should) be excluded from the US exceptions for high-taxed income. Nor is it clear how a Pillar Two tax could be ineligible for the US foreign tax credit but nevertheless result in a deemed dividend inclusion.
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