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Ethan Kroll

Ethan Kroll is a partner in the Los Angeles office and a member of the Firm's tax practice group. He contributes regularly to the Tax Management International Journal's Leading Practitioner Commentary and speaks frequently on international tax issues. Previously, he was a principal at a Big Four accounting firm.

On 11 December 2023, Treasury and the IRS issued Notice 2023-80 (the “Notice”), which represents the US government’s first attempt to address the US federal income tax implications of Pillar Two. The Notice provides guidance on certain foreign tax credit and dual consolidated loss issues that arise in the context of Pillar Two. The Notice also extends the period of relief for the 2021 final foreign tax credit regulations until more guidance is issued.