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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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Treasury’s Latest Effort to Prop Up Pillar 2

  • By Mindy Herzfeld

Mindy Herzfeld examines recently proposed dual consolidated loss regs and questions whether the regs are justified by the legislative history, or whether Treasury has exceeded its authority under Loper Bright Enterprises Inc. v. Raimondo.

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