Credits

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.

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.

Regs. on Foreign Tax Credit Splitter Arrangements

The IRS issued regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and on the application of the “anti-splitter” rules of Sec. 909.  

Congress Votes to Limit Use of Foreign Tax Credits

P.L. 111-226 makes changes to how corporations can use the foreign tax credit and also terminates the advance refundability of the earned income credit (under Sec. 3507), effective for tax years beginning after December 31, 2010.

Tax Insider Articles

DEDUCTIONS

Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.