CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations

In this episode, we discuss the international tax provisions in the recently released proposed CAMT regulations, including how the proposed regulations expand the reach of the special scoping rule for foreign-parented groups, provide (mostly) taxpayer-favorable rules to address CFC double counting, and import foreign tax credit limitations and section 482 into the CAMT universe.