Foreign tax credit: Changing from cash to accrual basis

Regulations provide regulatory authority for Treasury’s long-held position that an individual taxpayer who elects on a timely filed return to claim the foreign tax credit on the cash basis may not change to the accrual basis on an amended return.

Tax credit did not independently arise under treaties

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.

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.

How to treat foreign tax credits

The IRS issued final and proposed regulations covering a variety of issues involving deductions and credits for foreign taxes.

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.

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