Refundable credits and foreign tax credits
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.
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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.
The IRS issued guidance prohibiting corporations from taking foreign tax credits for taxes without repatriating the earnings to the United States.
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.
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.
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.
TECHNOLOGY
COVID-19 upended tax season. Did CPAs’ tax software help them cope? Read the results of our annual tax software survey
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.