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What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement

January 18, 2022 By Edward Tanenbaum and Stefanie Kavanagh

Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application of the foreign tax credit. The IRS seeks to modernize regulations to mitigate double taxation of foreign-source income Many of the final regulations follow the proposed regulations, but some were modified based on comments from taxpayers Gray areas remain, including how reasonably similar a foreign rule must be Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: attribution requirement, FTC, international tax, jurisdictional nexus requirement, OECD, Pillar One, regulations, Tax

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

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

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.

Filed Under: Federal Tax Advisory, Tax Reform Tagged With: 2017 Tax Act, dividend income, foreign tax credits, FTC, Section 902, Section 960, Setion 245A, tax credits

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

Filed Under: International - Corporate Tax Planning, International - Inbound, International - Outbound, International Tax Advisory Tagged With: final regulations, foreign tax credit, foreign tax credit splitter, FTC, hybrid instrument, loss sharing, reverse hybrid, section 909

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