New International Tax Provisions Take Aim at Foreign Tax Credit Planning But Also Provide Some Relief Under Section 6501(c)(8)

By Carol Tello and Giovanna Sparagna On August 10, 2010, President Obama signed into law the Education Jobs and Medicaid Assistance Act, P.L. 111-226, which provides funds to the states for teachers' salaries and Medicaid costs. To fund this bill, Congress enacted all but one of the international...

Foreign Tax Credit, Partnerships and Disregarded Entities: The Latest Rules

[Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, § 12.02[3][a][ii][B] (Matthew Bender).] The foreign tax credit is the international taxpayer's chief defense against double taxation of the same items of income, once by...