Foreign tax credits

Final regs. issued on foreign tax credits

The IRS officially released final regulations providing guidance on determining foreign tax credits. The regulations include changes necessitated by the law known as the Tax Cuts and Jobs Act.

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.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

PRACTICE MANAGEMENT

2019 tax software survey

This annual survey shows how CPAs rate the tax preparation software they used during last tax season and how it handled the recent tax law changes.