Credits
Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries.
A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties.
This item focuses on the potential increase in the Sec. 904(a) foreign tax credit limitation when PTEP
is distributed by a CFC to its corporate “U.S. shareholder.”
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
This item discusses how new rules would affect taxpayers’ ability to claim FTCs for foreign income taxes that are offset with refundable tax credits in a foreign jurisdiction.
The IRS issued final and proposed regulations covering a variety of issues involving deductions and credits for foreign taxes.
Treasury and the IRS temporary regulations include rules for determining foreign income taxes
deemed paid under Sec. 960, which pertains to the “deemed paid” foreign tax credit.
The IRS issued final and proposed regulations covering a wide variety of issues involving deductions and credits for foreign taxes.
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase 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.
The IRS issued final regulations on the Sec. 951A global low-taxed income inclusion and foreign tax credits, finalizing proposed rules issued in October and December 2018.
The IRS issued proposed regulations on the determination of the foreign tax credit after the changes in the law made by the Tax Cuts and Jobs Act.
The IRS issued proposed regulations on the determination of the foreign tax credit after the changes in the law made by the Tax Cuts and Jobs Act.
Although a company might in the future receive a refund of foreign taxes paid, it was entitled to claim
foreign tax credits.
This item illustrates how challenging it can be to
use foreign tax credits on qualified dividends.
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.
This article discusses some requirements of Form 1116 and the adjustments’ directions as laid out in Publication 514.
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 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.
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.
