This session will provide an overview of the Global Anti-Base Erosion (GloBE) Rules that were published in December of 2021 and will include a discussion of recent administrative guidance clarifying the application of various aspects of the rules. Topics will include how to determine whether a corporate group is in-scope, how to calculate liability under the rules and how to allocate liability among members of a corporate group. We will also address specific questions about priority between the GloBE rules and various domestic tax regimes, the treatment of certain tax credits generated by flow-through investments and allocating taxes paid under blended CFC tax regimes. CLE credit will be provided.

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