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Final FTC Regulations Cause Double Taxation — Burden(s) Fall on Taxpayers

Get a detailed overview of the most important foreign tax credit regulations to be issued in the last 40 years with this comprehensive report from Bloomberg Tax and Baker McKenzie.

These new regulations dramatically modify the analysis for determining whether a foreign levy is a creditable foreign tax, and taxpayers will be shocked to learn that many common previously creditable foreign taxes are no longer creditable.

Because of the breadth and importance of these changes, the coverage in this report is broken down into a three-part series that will examine:

  • Changes to the “net income tax” definition and other changes in Reg. §1.901-21 that restrict the ability of taxpayers to claim a foreign tax credit;
  • Changes to the withholding and substitute tax rules in §903 that dramatically reduce the types of services and royalty withholding taxes that can qualify as creditable foreign taxes; and
  • Changes to the disregarded payment rules in Reg. §1.861-20, the foreign tax credit timing rules under §901 and §905, and other foreign tax credit rules that taxpayers should be aware of

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