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Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

February 17, 2021 By Brian Harvel and April McLeod

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes.

  • What is the new jurisdictional nexus requirement?
  • Why is Treasury worried about Europe’s digital services taxes?
  • What are the arguments against the new nexus requirement?

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: foreign tax credit, FTC, Income Tax, IRS, nexus, OECFD, Organisation for Economic Co-operation and Development, Treasury

About Brian Harvel

Brian Harvel is a partner in the Federal & International Tax Group whose practice focuses on complex tax structuring and planning for a wide range of domestic and international business entities.

[Read Bio]

About April McLeod

April counsels her clients through the labyrinth of federal and international tax laws.

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