The IRS has released two pieces of interim guidance on its revised administrative policy for valid research credit refund claims. On January 3, 2022, the IRS issued procedural guidance for applying the revised administrative policy. On January 5, the IRS published a corresponding set of frequently asked questions (FAQs) on the policy. Both the guidance […]
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Michigan Enacts PTE Tax Election As Workaround To $10K SALT CAP
Michigan Governor Whitmer signed H.B. 5376 into law on December 20, making Michigan the latest state to allow pass-through entities (PTEs) the option to be taxed at the entity level. The new PTE regime creates a workaround for owners of PTEs doing business in Michigan to the $10,000 federal cap on state and local tax (SALT) deductions […]
Read moreOECD Releases Pillar Two Model Rules To Bring Global Minimum Tax Into Domestic Legislation
The OECD on December 20 released model rules to assist the 137 jurisdictions that agreed to the Inclusive Framework/G-2- Pillar Two framework to implement into domestic legislation a 15% minimum tax on those multinational enterprises (MNEs) that fall within its scope. The model rules fill in the details regarding Pillar Two of the agreement announced […]
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