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Section 902

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

Tax Act: Vote and Value

January 2, 2018 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory, Tax Policy, Tax Reform Tagged With: Controlled Foreign Corporations, Section 902, Tax Act, Tax Cuts and Jobs Act

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