treatment results in either materially less income or a materially greater amount of foreign tax credits
than would be available if the foreign law controlled the U.
He also assists companies with foreign tax credit
utilization, foreign treasury and cash flow management, recapitalization of foreign operations to enhance foreign earnings repatriation efficiency and reduce foreign tax burdens.
The foreign tax credit
(FTC) is designed to prevent the double taxation of income that often results from international transactions.
The notice provides guidance on the application of the new look-through rules and the transition from the previous treatment The transition issues addressed include the carryover and carry-back of excess foreign tax credits
and the treatment of separate limitation losses and overall foreign losses.
Many large banks other than BNY engaged in STARS transactions with Barclays, resulting in similar enormous foreign tax credit
Corporations whose primary business was manufacturing accounted for the largest share of foreign income, tax, and foreign tax credit
The IRS argues that allocations by foreign tax partnerships without corresponding income do not give rise to the double taxation that is the economic basis for the foreign tax credit
, and that these types of allocations should not be allowed.
909 foreign tax credit
splitter event provisions that were enacted in August 2010 as part of the Education Jobs and Medicaid Assistance Act of 2010, P.
Two important international tax concepts that have emerged over the years are the corporate foreign tax credit
and controlled foreign corporations.
Tim Tuerff of Deloitte Tax listens to a question about computing the foreign tax credit
implications of repatriated earnings.
corporate seller cannot use this portion of the Section 1248 gain to increase the amount of its foreign tax credit
The Iowa district court where this case originated viewed the ADR transactions as tax motivated and concluded the only change in IES's economic position as a result of the ADR transactions was the transfer of the foreign tax credit