FTC

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. [...]Read more

Foreign Tax Credits’ Demise

February 1, 2018 By Jasper L. (Jack) Cummings, Jr.

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.

Few Changes in Final Rules on Foreign Tax Credit Splitters

February 17, 2015 By Heather Ripley

On February 9, 2015, the U.S. Treasury released final regulations on foreign tax credit (FTC) splitting arrangements (the “2015 Regulations”). The final rules, released the same day that the 2012 temporary and proposed regulations were set to expire, offer some definitional and other clarifications and add useful illustrations. But for the most part, the 2015 Regulations adopt the prior proposed and temporary regulations, including the exclusive list of FTC splitter arrangements. Notably, the final rules fail to address several “mechanical issues” (i.e., issues concerning the tracking [...]Read more