Posts by Victoria Bogdanovich

Under the consistency rule in Temp. Regs. Sec. 1.861-9T(f)(3)(iv), for purposes of calculating its foreign tax credit, a taxpayer could...

By a vote of 51 to 50, the U.S. Senate on Sunday passed a budget reconciliation bill, H.R. 5376, now known...

A bankruptcy court held that a couple’s tax return filing allowed a related tax debt to be discharged in bankruptcy,...

Transfer-pricing disputes have a tendency to protract themselves over a number of years and discrete stages. For one thing, the uncertainties...

On Dec. 28, 2021, Treasury and the IRS issued final foreign tax credit regulations (T.D. 9959) that were officially published...