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Personalization, Analytics, and Digital Platforms CMOs explore how advanced analytics, AI, and cloud platforms are enabling...
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- 1 – Where was Pillar Two five years ago?
- 4:00 – HOW does the Pillar TWO administrative guidance in
February 2023 fit broadly into the model - 5:35 – What did the administrative guidance tell us about blended CFC
regimes and GILTI? - 8:10 – How do the rules address a scenario where a US multinational
or US holding company has CFCs that are all above the 13.125% tax
rate under the GloBE calculation? - 10:20 – A press release from IJS Treasury came out the same day as
the administrative guidance that claimed the guidance provided
certainty on several key issLB, including “protection of the Low
Income Housing Tax Credit as well as Green Tax Credits including
those that were included in the Inflation Reduction Act.” Does this
OECD guidance provide such protection? - 1 1 – Generally, what types of credits are ‘good’ covered taxes?
- 12:15 – What did the guidance provide regarding tax equity
structures? - 13:50 – In addition to the covered taxes two of the most
common provisions mentioned are related to loss-making jurisdictions
and transition vmod transactions.
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