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Proposed Disregarded Payment Loss Rules Create Traps for the Unwary
Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming. Under the proposed regulations, disregarded payments from a foreign disregarded entity to its domestic corporate parent can give rise to a US income inclusion without any offsetting…
#corporate parent#D/NI#DCL#deduction#deduction/no inclusion#disregarded payment loss#DPL#dual consolidated loss#foreign tax#foreign use#IIR#income inclusion rule#multinational#Pillar Two#QDMTT#qualified domestic minimum top-up tax#Section 1503(d)#taxpayers#top-up tax#US Department of the Treasury
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Chile's Daniel Jadue Groundbreaking Bet: A People's Real Estate - teleSUR tv HTTPS (press release) (blog)
http://dlvr.it/QDMTTs
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