Guidance Regarding the Foreign Tax Credit and Dual Consolidated Losses in Relation to the GloBE Model Rules, and Extension and Modification of Temporary Relief in Notice 2023-55 (Notic e 2023-80)

6 organizations filed 6 public comments on Guidance Regarding the Foreign Tax Credit and Dual Consolidated Losses in Relation to the GloBE Model Rules, and Extension and Modification of Temporary Relief in Notice 2023-55 (Notic e 2023-80), at the Internal Revenue Service. The comment window closed 900d ago.

Abstract

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations under §§ 59(l), 78, 704, 901, 903, 951A, 954, 960, and 1503(d) of the Internal Revenue Code (Code) to address the application of those provisions, including the foreign tax credit rules and the dual consolidated loss rules, to certain types of taxes described in the “Tax Challenges Arising from the Digitalisation of the Economy - Global Anti-Base Erosion Model Rules (Pillar Two)” (GloBE Model Rules).

Commenters (6)

• Alliance for Competitive Taxationtrade assoc.

  1 filing · confidence 85%
• American Council of Life Insurerstrade assoc.

  1 filing · confidence 85%
• Information Technology Industry Counciltrade assoc.

  1 filing · confidence 97%
• Medical Device Competitiveness Coalitiontrade assoc.

  1 filing · confidence 85%
• National Association of Manufacturers (NAM)trade assoc.

  1 filing · confidence 97%
• National Foriegn Trade Counciltrade assoc.

  1 filing · confidence 85%