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The Changing Landscape of the Foreign Tax Credit Regime

Introduction The tax landscape is changing for the amount U.S. multinational corporations may claim through the foreign tax credit. This change is the result of the Statutory Pay-As-You-Go Act of 2010 that requires any increased spending must be offset by a corresponding increase in revenue. [1...

The Repeal of the 80/20 Regime

On August 10, 2010, the President signed into law the Education, Jobs and Medicaid Assistance Act , P.L. 111-226, which, although not evident in the name of the Act, contained certain key foreign tax credit provisions and other rules that significantly affect U.S. multinational corporations. The...

Foreign Tax Credit Splitting and Application of Section 909 to Pre-2011 Taxes

IRC Section 909 provides that a foreign tax credit splitting event cannot be taken into account for federal income tax purposes before the taxable year in which the taxpayer takes the related income into account. IRC Section 909 was added by the Education, Jobs and Medicaid Assistance Act , and became...

The Elusive Basis Problem of the Foreign Tax Credit Limitation

As we know, Congress tinkered with the foreign tax credit (FTC) rules in 2010 in a number of ways. One of those changes was to add Section 901(m) (" Denial of foreign tax credit with respect to foreign income not subject to United States taxation by reason of covered asset acquisitions ") to...