6511(d)(3)(A) states that the 10-year limitation period applies only to refund claims when a foreign tax credit had been allowed. Because the options to deduct or credit foreign taxes are mutually ...

As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the ... that the base of the tax allowed for the respective deductions associated to earning of the income, such ...

but the TCJA changed several provisions in the Foreign Tax Credit, including repeal of section 902, which allowed deemed-paid credits in connection with dividend distributions based on foreign ...

The Eleventh Circuit Court of Appeals recently held that a life insurance company did not breach its fiduciary duties by retaining the benefits that it derived from foreign tax credits.

Such expansive changes to the foreign tax credit rules overstep Treasury ... eliminated a substantial amount of double taxation and allowed U.S.-headquartered companies to operate on more ...

The United States taxes citizens on their income, no matter where it's earned. Here's how to lower the tax bill. Many, or all, of the products featured on this page are from our advertising ...

Though the court previously allowed class certification in the case ... Income Security Act fiduciary duty of loyalty by receiving and retaining foreign tax credits for the international investment ...

For example, if John owed $10,000 in U.S. taxes and had paid $4,000 in foreign taxes, the foreign tax credit could reduce his U.S. tax bill by $4,000. The foreign tax credit helps prevent double ...

Among its provisions was a disallowance of credits or deductions for foreign taxes paid on dividends eligible for the DRD. New regs clarify the operation of the disallowance. Published on January ...

While the AMT limits certain deductions and credits, it does allow a portion of the foreign tax credit to reduce U.S. tax liability. However, specific rules govern how much of the credit applies ...