Foreign tax 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.

Newsletter Articles

SPONSORED REPORT

States look to unclaimed property for revenue

State audits of abandoned and unclaimed property (AUP) have exploded in recent years. This report outlines the escheat process, common types of AUP, how different states are handling it and how companies can plan for potential audits and liabilities.

DEDUCTIONS

Understanding the new Sec. 199A business income deduction

The new deduction allows certain business owners to keep pace with the significant corporate tax cut provided by the Tax Cuts and Jobs Act.