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Rafic H. Barrage

Rafic H. Barrage is a Principal in Baker & McKenzie's North America Tax Practice Group. He has almost 20 years of broad international tax planning experience. Mr. Barrage advises clients on a variety of issues, including restructuring and entity rationalization, IP migration, supply-chain planning and principal structures, the taxation of digital transactions, deferral and repatriation planning, foreign tax credit planning, and post-U.S. tax reform tax optimization. Mr. Barrage is a recognized leader in his field by The Legal 500 (2010 and 2011) (described as one of the "impressive younger partners" and "technically very strong") and as one of the Tax Controversy Leaders by the International Tax Review (2011 and 2012). Mr. Barrage is an Adjunct Professor of Law at Georgetown University Law Center, where he has taught the International Tax Business Planning workshop since 2013.

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.

Asia Pacific tax authorities are actively seeking to reduce tax leakages, non-compliance, and what they perceive to be tax avoidance activities. To help you position your business for success in an era of ever-changing tax rules and intense scrutiny, our subject matter experts from across the region and globally will come together to examine key developments. We will discuss the impact of emerging trends and current issues on your business models and strategies, sharing practical tips on how you can maximize opportunities to achieve the best risk mitigation outcomes.

Following our first two short videos on key trends (see here) and the semiconductor supply chain (see here), Baker McKenzie is pleased to launch the third in our Biden Supply Chain Policy video series focused on the large-capacity batteries supply chain. This is another of the critical supply chains that has been a particular focus of the Biden Administration’s supply chain policies.

In an era where supply chain disruptions and risks are regular front-page news, the Biden Administration has been undertaking a range of initiatives intended to create resilient supply chains that reflect the administration’s policies around national security, foreign policy, human rights and the US economy.