In 1998 the IRS and the Treasury Department got the attention of the outbound international tax community by issuing Notice 98-5. The notice sought to challenge certain tax-motivated transactions that generated foreign tax credits (FTCs) by testing their substance under an economic profits test. The transactions described in Notice 98-5 were later included as "listed transactions" subject to the tax shelter disclosure, registration and list maintenance requirements.
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
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