NYSBA Tax Section Comments on Pillar 2 FTC Considerations
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NYSBA Tax Section Comments on Pillar 2 FTC Considerations
The New York State Bar Association Tax Section has submitted a report to the U.S. Treasury Department and the IRS regarding foreign tax credit considerations related to the OECD’s pillar 2 model rules, discussing considerations raised by pillar 2 taxes under the current IRS section 901, section 904, and section 960 rules; raising policy considerations for granting a credit for those taxes; and recommending related guidance.
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