Loren Ponds will moderate part three of the DC Bar's International Tax Series, "Interaction of U.S. International Tax Rules with Pillar Two," on March 20, 2024. The panel will discuss recent guidance (Notice 2023-80) addressing the creditability of certain top-up taxes consistent with the Pillar Two Global Anti-Base Erosion (GloBE) Model Rules and whether the calculation of a Pillar Two tax triggers the recapture of "legacy" dual consolidated losses (DCLs). This panel will also consider unresolved questions, including the treatment of current DCLs and the potential interaction of U.S. anti-hybrid rules with Pillar Two.