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Treasury Welcomes Clear Guidance on Pillar Two Global Minimum Tax and Tax Credit Protections

The OECD/G20 Inclusive Framework released a package of technical and administrative guidance that achieves clarity on the global minimum tax on multinational corporations known as Pillar Two. Further, it provides critical protections for important tax incentives, including green tax credit incentives established in the Inflation Reduction Act. Pillar Two provides for a global minimum tax on the earnings of large multinational businesses, leveling the playing field for U.S. businesses and ending the race to the bottom in corporate income tax rates. This package follows the release of the Model Rules in December 2021, Commentary in March 2022 and rules for a transitional safe harbor in December 2022. The guidance will be incorporated into a revised version of the Commentary that will replace the prior version.

Additionally, the package includes guidance on over two dozen topics, addressing those issues that Inclusive Framework members identified are most pressing. This includes topics relating to the scope of companies that will be subject to the Global Anti-Base Erosion (GloBE) Rules and transition rules that will apply in the initial years that the global minimum tax applies. Additionally, it includes guidance on Qualified Domestic Minimum Top-up Taxes (QDMTTs) that countries may choose to adopt.

“The continued progress in implementing the globalminimum tax represents another step in leveling the playing field for U.S. businesses, while also protecting U.S. workers and middle-class families by ending the race to the bottom in corporate tax rates,” said Assistant Secretary of the Treasury for Tax Policy Lily Batchelder. “We welcome this agreed guidance on key technical questions, which will deliver certainty for green energy tax incentives, support coordinated outcomes and provide additional clarity that stakeholders have asked for.”

FL - Guidance issued on affidavit required to claim exemption for boats sold to nonresident purchasers

Guidance is issued regarding changes that have been made to the affidavit required to claim the sales tax exemption for […]

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FL - Guidance issued on affidavit required to claim exemption for boats sold to nonresident purchasers

FL - Storm Extensions Offered

The Florida Department of Revenue is offering corporate income tax return filing extensions for businesses in counties affected by severe […]

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FL - Storm Extensions Offered

FL - Credit for employing individuals with unique abilities discussed

Florida issued guidance that discusses the new corporate income tax credit for employing individuals with unique abilities. The guidance includes […]

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FL - Credit for employing individuals with unique abilities discussed

FL - Indexed tax rate on asphalt for 2024-2025 announced

Florida issued guidance that discusses the new corporate income tax credit for employing individuals with unique abilities. The guidance includes […]

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FL - Indexed tax rate on asphalt for 2024-2025 announced

Inflation Adjusted Credit Rate for Carbon Dioxide Sequestration Released, Notice 2024-39

The IRS has released the inflation adjustment factor for the credit for carbn dioxide (CO2) sequestration under Code Sec. 45Q for 2024. The inflation adjustment factor is 1.3877, and the credit is $27.75 per metric ton […]

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Inflation Adjusted Credit Rate for Carbon Dioxide Sequestration Released, Notice 2024-39

IRS Tightens Scrutiny on Employee Retention Credit Claims, IR-2024-169

The IRS has announced plans to deny tens of thousands of high-risk Employee Retention Credit (ERC) claims while beginning to process lower-risk claims. The agency’s review has […]

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IRS Tightens Scrutiny on Employee Retention Credit Claims, IR-2024-169

Seniors Warned of Rising Impersonation Scams, IR-2024-164

The IRS has issued a warning about the increasing threat of impersonation scams targeting seniors. These scams involve fraudsters posing as government officials, including IRS agents, […]

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Seniors Warned of Rising Impersonation Scams, IR-2024-164

Clean Hydrogen Credit Inflation Factors and Applicable Amounts for 2023 and 2024 Released, Notice 2024-45

The IRS released the inflation adjustment factors and the resulting applicable amounts for the clean hydrogen production credit for 2023 and 2024. For 2023, the inflation adjustment factor is one, so the inflation adjusted applicable amounts are the same as those in Code Sec. 45V(b). Thus, the applicable amounts for a […]

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Clean Hydrogen Credit Inflation Factors and Applicable Amounts for 2023 and 2024 Released, Notice 2024-45

United States-Russia Tax Treaty To Be Suspended, Announcement 2024-26

The United States has provided formal notice to the Russian Federation on June 17, 2024, to confirm the suspension of the operation […]

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United States-Russia Tax Treaty To Be Suspended, Announcement 2024-26

IRS Highlights Home Energy Credits for Taxpayers, IR-2024-137

The IRS has advised taxpayers that making specific energy-efficient updates to their homes could qualify them for home energy credits. This guidance comes under the expanded provisions of […]

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IRS Highlights Home Energy Credits for Taxpayers, IR-2024-137