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Observations on Notice 2023-80: The Treasury Department and IRS' Preliminary Guidance on the Interaction of Foreign Tax Credit and Dual Consolidated Loss Rules With Pillar Two Taxes and the Extension of Notice 2023-55 Relief Period | Skadden, Arps, Slate, Meagher & Flom LLP

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice)...
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Implementation of Pillar Two of the Statement on a Two-Pillar Solution by the OECD/G20 Inclusive Framework: Bill adopted by the Chamber of Deputies

On 20 December 2023, the Chamber of Deputies adopted the bill on minimum effective taxation to transpose into national legislation Council Directive (EU) 2022/2523 of 15 December 2022 to ensure a worldwide minimum level of taxation for multinational enterprise groups and large domestic groups in the European Union.
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