13
Dec
Notice 2023-80 describes rules that would address the treatment of certain taxes, including Income Inclusion Rules (IIRs), Undertaxed Profit Rules (UTPRs), and Qualified Domestic Minimum Top-up Taxes (QDMTTs).
GloBE Model Rules and the FTC
Treasury and the IRS intend to issue proposed regulations consistent with the guidance regarding the following:
Creditability and deductibility of GloBE Top-up Taxes that, in computing the amount of tax, consider the amount of tax that other countries (including the United States) impose on the direct or...