The Association of International Certified Professional Accountants (AICPA) has formally requested guidance regarding the implementation of the Pillar Two framework, which is part of the recent G7 agreement on a Global Minimum Tax.
This framework is intended to operate alongside the US tax regulations for Multinational Enterprises (MNEs) and in conjunction with the Organisation for Economic Co-operation and Development (OECD) standards.
In its letter, the AICPA stresses the importance of timely guidance, and also raises issues related to substance-based non-refundable tax credits, specifically referencing the US section 41 research credit.
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