August 2019

IRS finalizes certain foreign tax credit regulations

In June, the IRS finalized certain proposed regs pertaining to the foreign tax credit (FTC). This article highlights changes to the rules that address the interaction between the FTC and Internal Revenue Code rules on not applying the net operating loss deduction when calculating the Sec. 965 transition tax.

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FATCA: Explanations of key certifications and periodic review requirements

The IRS has revised its general frequently asked questions (FAQs) on the Foreign Account Tax Compliance Act. This article outlines the three changed FAQs, which focus on certification and periodic review requirements.

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IRS will allow foreign tax credit for previously noncreditable French taxes

The IRS has issued a statement saying it will no longer challenge claims for foreign tax credits (FTCs) related to the French Contribution Sociale Generalisee and Contribution au Remboursement de la Dette Sociale taxes. This article explains the ramifications and considers the U.S. Tax Court case that spurred the tax agency’s decision.

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