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ON DEMAND: International Tax Series and Financial Products Series: Interaction of U.S. International Tax Rules with Pillar Two
This panel will address recent guidance (Notice 2023-80) addressing the creditability of certain top-up taxes consistent with the Pillar Two Global Anti-Base Erosion (GloBE) Model Rules and whether the calculation of a Pillar Two tax triggers the recapture of "legacy" dual consolidated losses (DCLs). This panel will also discuss any consider unresolved questions, including the treatment of current DCLs and the potential interaction of U.S. anti-hybrid rules with Pillar Two. Renew or join Communities to receive the best discount on registration. Click here to log in and join Communities.
Are you a current law student and looking to register for one of our programs? Learn about the D.C. Bar Law Student Community and attend most individual programs at a discounted rate. Find out more here. Sponsored by:International Tax Committee of the D.C. Bar Taxation Community Co-sponsored by: Financial Products Committee of the D.C. Bar Taxation Community Related Community of Interest: D.C. Bar International Law Community Speakers:
Ryan Bowen, International Tax Senior Manager, Washington National Tax, Deloitte
Marcus Heyland, Principal, Washington National Tax, KPMG
Tracy Villecco, Senior Technical Reviewer, Branch 3, Office of the Associate Chief Counsel (International), Internal Revenue Service
Andrew Wigmore, Senior Counsel, Branch 4, Office of the Associate Chief Counsel (International), Internal Revenue Service
Loren Ponds, Member, Miller & Chevalier Chartered (Moderator)
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$40.00
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$30.00
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$0.00
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$15.00
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$15.00
Government and Nonprofit Attorneys
Standard
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$15.00
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