The U.S. IRS has issued Notice 2023-80, which provides guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE Model Rules, as well as the Extension and Modification of the Temporary Relief provided in Notice 2023-55.
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Guidance Regarding the Foreign Tax Credit and Dual Consolidated Losses in Relation to the GloBE Model Rules, and Extension and Modification of Temporary Relief in Notice 2023-55
Notice 2023-80
SECTION 1. OVERVIEW
P.01 Purpose.
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