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Use of Extrinsic Evidence and Quantitative Analysis in PPL Corp. v. Comm'r

Despite the quantity of ink spilled by the Tax Court in its lengthy review of the factors which govern a creditable foreign income tax, the key takeaway for corporate tax counsel and their advisors from PPL Corp. & Subsidiaries v. Comm'r , 2010 U.S. Tax Ct. LEXIS 31 (T.C. Sept. 9, 2010) is the...

Practical Tax Considerations Relevant to U.S. Totalization Agreements

Totalization agreements are one of the best kept secrets in the international tax arena. Very few practitioners know they exist, and fewer still know what those agreements do... ... Totalization Agreements: What They Are A totalization agreement is a bilateral treaty between two countries that...