Andersen Managing Director Joe Calianno's comments are featured in the recent Tax Notes article, U.S. Income Analysis Complicates Pillar 2 FTC Creditability. The article covers new IRS guidance laying the foundation for future rulemaking on the interaction between foreign tax credit rules, dual consolidated loss (DCL) rules and other rules with the Pillar Two rules. Joe mentions how the introduction of the Pillar Two rules raises several issues relating to the application of the DCL rules, including whether there is a foreign use of a DCL and highlights the relief identified in the notice relating to certain legacy DCLs.