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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.

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

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

[Read Bio]

About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

[Read Bio]

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