Adjusting the foreign tax credit for an economic recession

Article Abstract:

The foreign loss recapture rule in IRC 904(f), for foreign tax credits, creates an inequity for US companies that experience a loss in the US. The rule was designed to prevent abuse of the credits through double benefit but in effect results in double taxation on domestic losses. Therefore, domestic losses should be able to offset foreign profits in excess of the foreign tax credit limitation to create a level playing field for multinational corporate competition.

Analysis, Interpretation and construction, Tax treaties

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Qualified intermediaries - caught in the complexity of new U.S. withholding requirements

Article Abstract:

The author present an overview of the foreign qualified intermediary tax application procedures and examines the burdens associated with such status.

Tax administration and procedure, Tax administration, Withholding tax

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New consolidated return OLF regulations sacrifice principles to maximize revenue

Article Abstract:

The author examines the overall foreign loss rules and their impact on consolidated return principles.

Consolidated tax returns

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