Tax relief through the foreign tax credit
(or a foreign tax deduction) won't help, though, if you hold a foreign stock fund in a tax-deferred account such as an IRA.
FOGEI and FORI Foreign Tax Credit
party is a person eligible to claim a foreign tax credit
under IRC [section] 901(a), including a credit for taxes deemed paid under section 902 or 960, for all or a portion of foreign tax paid.
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.
The practical alternative might be for taxpayers to plan around this roadblock when evaluating their foreign tax credit
position and use strategies.
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.
Financial statement prepares must then deal with the practical considerations associated with net operating loss, capital loss, minimum tax credit, and foreign tax credit
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit
Two important international tax concepts that have emerged over the years are the corporate foreign tax credit
and controlled foreign corporations.