US Treasury provides guidance on the creditability of Pillar Two taxes, grants relief for pre-GloBE DCLs and extends temporary relief from FTC regulations
|Tax Alerts, Legislation & Policy, Na ...|United States
The Notice indicates that a QDMTT is generally creditable, whereas an IIR may or may not be creditable depending on whether the taxpayer's US federal income tax liability may be included in its computation.
The Notice provides that the GloBE Rules will not cause the foreign use of a DCL incurred in a pre-GloBE tax year, subject to an anti-abuse provision.
The Notice extends the relief period from the FTC Creditability Regulations described in Notice 2023-55 until further guidance is issued.
Taxpaye…
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