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...

ALERT: Recently Enacted Provisions Relating to the Foreign Tax Credit

By Rebecca I. Rosenberg Several new foreign tax credit provisions were signed into law on August 10, 2010, and take effect in 2011. Significant new rules include the anti-splitting provision of section 909, the basis difference rule of section 901(m), the section 956 deemed paid credits rule of...

Puerto Rico Enacts New Excise Tax That Impacts U.S. Companies

By Damon M. Lyon, David G. Noren , Lowell D. Yoder , Rachel E. Aaronson , Robert A. Clary II A temporary excise tax recently enacted in Puerto Rico will have a significant impact on U.S.-based multinational groups conducting, or considering conducting, manufacturing activities in Puerto Rico. ...

Procter & Gamble v. U.S. and the FTC Noncompulsory Payment Requirement

One of tax life's significant attractions for U.S. multinationals is the capacity to claim a foreign tax credit (FTC) for taxes paid in foreign jurisdictions. Much like many attractions, however, the opportunity to avoid double taxation by having recourse to that unilateral U.S. credit mechanism...

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...

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). Available also in print at the LexisNexis® Store . ] The foreign tax credit is the international taxpayer's chief defense against...