Brian H. Jenn

The Inflation Reduction Act: Overview of New Corporate Minimum Tax

OECD, USA - August 10 2022 On August 7, 2022, the US Senate passed the Inflation Reduction Act of 2022 (the Act), a budget reconciliation bill recently introduced by Senate…

Alex Cheng-Yi Lee, Jeffrey Maydew, Barry J. Quirke, John Robert

New US Treasury regulations deny foreign tax credits for previously creditable foreign taxes

OECD, USA - May 9 2022 New regulations adopt a new "attribution requirement" that restricts the availability of foreign tax credits (FTCs) to foreign taxes that the US…

An overview of OECD Pillar 2

OECD - May 9 2022 Potential new tax rules would significantly impact the taxation of multinational groups, introducing new complexity to international taxation and…

Romain Desmonts, Annette Keller, Alessio Persiani, Dr. Dirk Pohl, James Ross, Andrea Tempestini, Antoine Vergnat

OECD Pillar 2 Q&A

OECD - February 14 2022 The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework's project is to ensure that multinational groups of…

Romain Desmonts, Annette Keller, Alessio Persiani, Dr. Dirk Pohl, James Ross, Andrea Tempestini, Antoine Vergnat

New Attribution Requirement Denies Foreign Tax Credits for Certain Withholding Taxes (And Other Taxes)

OECD, USA - January 20 2022 On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations)…