John BettAidan Barlow

Mar 12, 2024 | news.bloombergtax.com | Ethan Kroll |John BettAidan Barlow |Young-Eun Choi

It isn’t clear how §267A applies in a Pillar Two world, and Treasury and the IRS may want to think twice about incorporating Pillar Two into §267A, say Baker McKenzie practitioners. The Pillar Two rules combine the income and loss of all related entities that are located in the same jurisdiction for purposes of determining whether any Pillar Two top-up tax is owed for that jurisdiction.