Foreign tax credit requires consistency
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...
Key tax provisions in the Senate reconciliation bill
Aug 19, 2022
By a vote of 51 to 50, the U.S. Senate on Sunday passed a budget reconciliation bill, H.R. 5376, now known...
Tax debt from late return is held discharged
Aug 16, 2022
A bankruptcy court held that a couple’s tax return filing allowed a related tax debt to be discharged in bankruptcy,...
Transfer pricing and MAP: Common traps for the unwary
Aug 9, 2022
Transfer-pricing disputes have a tendency to protract themselves over a number of years and discrete stages. For one thing, the uncertainties...
Foreign tax credit: Changing from cash to accrual basis
Aug 4, 2022
On Dec. 28, 2021, Treasury and the IRS issued final foreign tax credit regulations (T.D. 9959) that were officially published...
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