Tag Archives: Section 902

Foreign Tax Credits’ Demise

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Our Federal Tax Group delves into whether foreign withholding taxes are creditable under the Tax Cuts and Jobs Act.

  • Now? Or never?
  • One example
  • Stacking the deck

Read the full advisory here.

Tax Act: Vote and Value

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Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

  • U.S. shareholders
  • The vote or value definition
  • Controlled foreign corporations

Click here to read the full advisory.