Although a company might in the future receive a refund of foreign taxes paid, it was entitled to claim
foreign tax credits.
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Credits
The challenge of maximizing the foreign tax credit on qualified dividends
This item illustrates how challenging it can be to
use foreign tax credits on qualified dividends.
Wells Fargo wins partial victory on STARS transaction
The Tax Court held that the loan portion of a STARS transaction was not a sham but that the company was subject to tax penalties.
Adjustments of foreign capital gains and losses for the foreign tax credit
This article discusses some requirements of Form 1116 and the adjustments’ directions as laid out in Publication 514.
Sec. 901(m) Temporary Regulations Apply to Covered Asset Acquisitions
The IRS issued temporary regulations designed to prevent taxpayers from misapplying the Sec. 901(m) statutory disposition rule in certain cases when a foreign asset is disposed of.
IRS Plans Regs. on Sec. 909 Foreign Tax Credit Splitter Arrangements
IRS describes regulations it intends to issue identifying as foreign tax credit splitter arrangements certain transactions undertaken by corporations in anticipation of foreign-initiated income tax adjustments.
Rules Govern Covered Asset Acquisitions Under Sec. 901(m)
The IRS issued temporary regulations that are designed to prevent taxpayers from misapplying the Sec. 901(m) statutory disposition rule in certain cases when a foreign asset is disposed of.
IRS Restricts Foreign Tax Credit Splitter Arrangements
The IRS issued guidance prohibiting corporations from taking foreign tax credits for taxes without repatriating the earnings to the United States.
Rules for Partnership Allocations of Creditable Foreign Taxes Are Amended
Temporary regulations issued by the IRS amend an existing safe harbor that is used for determining whether allocations of CFTEs are deemed to be in accordance with the partners’ interests in the partnership.
Foreign Oil and Gas Tax Credits Subject to Separate Credit Limitations
A recharacterization of royalties as income tax in some countries results in a high rate of foreign tax imposed on foreign oil and gas income that can be creditable against the U.S. tax.
Regulations Clarify Partnership Allocations of Creditable Foreign Taxes
New rules released by the IRS are intended to improve an existing safe harbor for allocating creditable foreign taxes so that they are deemed to be in accordance with the partners’ interests in the partnership.
Foreign Tax Credit: When Is It Too Late to Change Your Mind?
The IRS has effectively made the 10-year window for switching between credit and deduction a one-way street that only allows a change from deduction to credit.
Final Rules Govern Foreign Tax Credit Splitter Arrangements
The IRS issued regulations that prohibit taxpayers from taking a foreign tax into account for federal foreign tax credit purposes before the tax year in which the taxpayer takes the related income into account.
Filing Protective Claims Following Redetermination of Foreign Tax Liability
U.S. multinationals that have undergone a tax audit in a foreign jurisdiction resulting in additional foreign tax liability may be able to file an amended U.S. return with the IRS to claim a credit for foreign taxes paid. A special 10-year period of limitation applies to refunds resulting from these claims.
The Creditability of Foreign Taxes: Form vs. Substance
The U.S. Supreme Court’s recent decision in PPL Corp is a significant development in determining which foreign taxes are creditable against U.S. income tax. This article examines the implications of the Supreme Court’s PPL decision, arguing that the Court’s decision highlights the flaws in the regulations many tax experts have previously identified.
Final Regs. Determine Amount of Tax Paid for Purposes of the Foreign Tax Credit
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Regs. Curb Artificially Generated Foreign Tax Credits
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Final Regulations Attack Artificially Generated Foreign Tax Credits
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit.
Local Country Tax Incentives and the Foreign Tax Credit
U.S. multinationals operating in foreign jurisdictions via subsidiary corporations may be shortchanging themselves when they account for the effect of local incentives on available foreign tax credits in the United States.
Sec. 901(m): Potential Trap for Partnership Transactions
New Sec. 901(m) limits the creditability of foreign taxes in certain acquisition transactions where a taxpayer receives a basis step-up for U.S. tax purposes but no corresponding basis step-up for foreign tax purposes.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
