The Knight Watch — Happy Holidays from Treasury and Internal Revenue Service!
Tax attorney Joshua Odintz authored an article in TAXES – The Tax Magazine analyzing recent IRS guidance on foreign tax credits and the Organization for Economic Cooperation and Development's (OECD) Pillar Two global minimum tax regime. The article examines IRS Notice 2023-80, which extends temporary relief from certain restrictive provisions in the 2022 final foreign tax credit regulations. Mr. Odintz also discusses the notice's provisions on the creditability of top-up taxes under the Pillar Two framework. His analysis provides timely insights for multinational companies assessing the impact of evolving international tax rules on their cross-border operations.