| Title |
Author |
Type |
Date |
Words |
| Foreign income taxes deemed paid and the PTEP rules. |
Heroux, Mark |
|
Oct 1, 2020 |
1134 |
| TEI Files Comments Regarding Proposed Regulations Addressing the Foreign Tax Credit. |
|
|
May 1, 2020 |
4238 |
| Claiming a Foreign Tax Credit: How Exhausted Do You Really Have to Be? Missteps by taxpayers in this area can be costly and result in avoidable double taxation. |
Morris, Robert C. |
Cover story |
Sep 1, 2019 |
4386 |
| TEI Comments on Proposed Foreign Tax Credit Regulations. |
|
|
May 1, 2019 |
2709 |
| IS THE TAX CUTS AND JOBS ACT GILTI OF ANTI-SIMPLIFICATION? |
Davis, Christine A. |
|
Mar 22, 2019 |
34157 |
| Varian Medical Systems and Forte International Tax Tackle GILTI/FDII and Foreign Tax Credits. |
Gasbarra, Mark; Pollard, Brian |
|
Mar 1, 2019 |
991 |
| GILTI, FDII, and FTC Guidance and International Tax Planning: How to decipher this complex stew, replete with interesting ingredients. |
Varma, Amanda |
|
Mar 1, 2019 |
4288 |
| Taxpayer's change to foreign tax deduction is ruled untimely: Extended limitation period of 10 years for refund claims applies only to foreign tax credit, Second Circuit affirms. |
Reichert, Charles J. |
|
Jan 1, 2019 |
724 |
| FROM SWITZERLAND WITH LOVE: SURREY'S PAPERS AND THE ORIGINAL INTENT(S) OF SUBPART-F. |
Fishbien, Nir |
|
Sep 22, 2018 |
26243 |
| PARTIAL REPEAL OF FOREIGN TAX CREDITS BY THE TAX CUTS AND JOBS ACT: RESULTING BEHAVIORAL INCENTIVES, SELF-HELP, AND NEW MECHANICS FOR SOME REMAINING PORTIONS OF THE CREDIT. |
Rosenberg, Rebecca |
|
Sep 22, 2018 |
40669 |
| Analysis of and reflections on recent cases and rulings. |
Beavers, James A. |
|
Mar 1, 2018 |
3643 |
| Adjustments of foreign capital gains and losses for the foreign tax credit. |
Schulman, Allen |
|
Jul 1, 2017 |
3520 |
| IRS plans regs. on sec. 909 foreign tax credit splitter arrangements. |
Hailey, Sean; Leyva, Natan |
|
Jan 1, 2017 |
1360 |
| Foreign oil and gas tax credits subject to separate credit limitations. |
Costa, Karen Leone |
|
Apr 1, 2016 |
2136 |
| If you can't beat them, join them: the U.S. solution to the issue of corporate inversions. |
DeAngelis, Scott |
|
Nov 1, 2015 |
13489 |
| BMC software: a hidden holding on the weight afforded to published guidance. |
Lardinois, Ryan; Heroux, Mark |
|
Oct 1, 2015 |
1328 |
| Foreign tax credit: when is it too late to change your mind? |
Ward, Travis S. |
|
Sep 1, 2015 |
1881 |
| Sec. 962 to the rescue. |
Polantz, Raymond M. |
|
Aug 1, 2015 |
2197 |
| Filing protective claims following redetermination of foreign tax liability. |
Curran, Kevin |
|
Jul 1, 2014 |
936 |
| Tax law - U.K. windfall tax constitutes U.S. income tax under I.R.C. 901(b)(1) - PPL Corp. v. Commissioner. |
Holland, David T. |
|
Jun 1, 2014 |
4583 |
| Final regs. determine amount of tax paid for purposes of the foreign tax credit. |
Raglan, Hubert; O'Connor, Margaret; Stevens, Matthew; Housman, Christopher J. |
|
Jan 1, 2014 |
288 |
| The creditability of foreign taxes: form vs. substance. |
Wilkinson, Brett R.; Wilkinson, Katherine |
|
Jan 1, 2014 |
4436 |
| Regs. curb artificially generated foreign tax credits. |
Schreiber, Sally P. |
|
Nov 1, 2013 |
275 |
| Is the offshore tax vacation over: politicians and business remain far apart on how to overhaul the U.S. corporate tax system in order to redomesticate billions on offshore assets. But the subject is no longer thought to be out of the question. |
Westfall, Christopher |
|
Oct 1, 2013 |
1852 |
| Local country tax incentives and the foreign tax credit. |
Ward, Travis S. |
|
Sep 1, 2013 |
2189 |
| When is a foreign tax creditable under sec. 901? |
|
|
Jan 1, 2013 |
816 |
| Guidance on foreign tax credit splitter transactions. |
Jones, Donald |
|
Sep 1, 2012 |
2121 |
| State taxation of trusts: credit for taxes paid to other states. |
Bergmann, Gregory A.; Johnson, Eric L. |
|
Sep 1, 2012 |
3851 |
| FTC "splitter" rules issued. |
Bonner, Paul |
|
May 1, 2012 |
700 |
| Foreign limitations on tax loss carryovers may affect US. foreign tax credits. |
Anderson, Kevin D. |
|
May 1, 2012 |
845 |
| Regs, on foreign tax credit splitter arrangements. |
Nevius, Alistair M. |
|
Apr 1, 2012 |
694 |
| U.S. sandwich structures in the international inbound context. |
Nevius, Alistair M. |
|
Mar 1, 2012 |
1831 |
| REGS shut down artificially generated FTCs. |
|
|
Oct 1, 2011 |
679 |
| TEI comments on proposed Canadian legislation. |
|
|
May 1, 2011 |
5593 |
| Emerging issues for non-U.S. shareholders in corporate inversions. |
Jones, Don; Park, Robin; Douglas, Roger |
|
May 1, 2011 |
1431 |
| The Education, Jobs, and Medicaid Assistance Act of 2010. |
Weber, Neal A. |
|
Apr 1, 2011 |
2302 |
| Form 5471 Penalties. |
Weber, Neal A. |
|
Apr 1, 2011 |
374 |
| TEI comments on proposed Canadian legislation. |
|
|
Mar 22, 2011 |
5593 |
| A tisket, a tasket: basketing and corporate tax shelters. |
Lederman, Leandra |
|
Mar 1, 2011 |
24355 |
| International tax law as a Ponzi scheme. |
Morgan, Ed |
|
Jan 1, 2011 |
21546 |
| Congress votes to limit use of foreign tax credits. |
Nevius, Alistair M. |
|
Oct 1, 2010 |
332 |
| Uncovering the covered asset acquisition rules. |
Kaplan, Joshua S.; Farrell, Jeffrey W.; Shein, Caren S. |
|
Sep 1, 2010 |
10748 |
| Profile of multinational businesses with inbound investments. |
Godfrey, Howard; Wiggins, Casper |
|
Mar 1, 2010 |
6051 |
| Repatriation strategies in a changing tax environment. |
Lysenko, Jonathan |
|
Jan 1, 2010 |
425 |
| Adopting or changing a foreign corporation's accounting method. |
Hui, Irene Pik-Wah |
|
Jul 1, 2009 |
1011 |
| U.S. tax effects of a foreign jurisdiction audit. |
Thompson, Bradley C.; Curran, Kevin M. |
|
Jul 1, 2009 |
646 |
| Expatriation and the new mark-to-market rules. |
Fava, Karl L. |
|
Jul 1, 2009 |
5724 |
| Automatic penalties for late forms 5471 and related forms. |
Sherr, Eileen Reichenberg |
|
Nov 1, 2008 |
409 |
| New Temp. Regs. under Sec. 905(c). |
Dash, Roopesh; Gupta, Sima; Landreneau, Frank |
|
Nov 1, 2008 |
2427 |
| Selected provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty. |
Carsalade, Rafael |
|
Nov 1, 2008 |
1635 |
| Tax credits become Blighty's secret weapon: imported production crews shooting in England can earn back upward of 20% of budget in rebates. |
Dawtrey, Adam |
Brief article |
Oct 20, 2008 |
332 |
| How to jump through the hoops: perseverance and patience are their own rewards when financing U.K. films. |
Dawtrey, Adam |
|
Oct 20, 2008 |
709 |
| IRS issues final "Killer B" regs. |
Nevius, Alistair M. |
|
Aug 1, 2008 |
353 |
| Adapting to the United Kingdom's new remittance basis rules. |
Whittall, Robert E. |
|
Aug 1, 2008 |
2407 |
| Foreign tax credits: reducing eight categories to two. |
Jones, Don |
|
May 1, 2008 |
1236 |
| Risk, return, and objective economic substance. |
Luke, Charlene D. |
|
Mar 22, 2008 |
20736 |
| Moving the "management and control" of a foreign corporation to achieve favorable U.S. tax results. |
Rubinger, Jeffrey L. |
|
Oct 1, 2007 |
5278 |
| D.C. Circuit finds that Central Bank of Brazil is "a person" other than Brazilian state for tax purposes where Bank "stood in" for ultimate beneficiaries of loan made by U.S. Company, thus removing need to apply Act of State doctrine. |
|
|
Aug 1, 2007 |
1163 |
| IRS targets foreign tax credit generators. |
Pulliam, Darlene |
|
Jun 1, 2007 |
249 |
| Compaq redux: implicit taxes and the question of pre-tax profit. |
Knoll, Michael S. |
|
Mar 22, 2007 |
15937 |
| Tax gap, legislative and regulatory initiatives focus of TEI's 57th Midyear Conference: new Ways & Means Chair, IRS Deputy Commissioner, and Treasury & OECD Officials Speak, FIN 48 commands attention. |
|
|
Mar 1, 2007 |
1078 |
| Proposed "technical taxpayer" regulations shut down guardian and reverse hybrid structures. |
Rubinger, Jeffrey L. |
|
Feb 1, 2007 |
4374 |
| Sourcing the "unsourceable": the cost sharing regulations and the sourcing of affiliated intangible-related transactions. |
Benshalom, Ilan |
|
Jan 1, 2007 |
31044 |
| Limits on refunds for NOL carrybacks. |
Curran, Kevin |
|
Jul 1, 2006 |
932 |
| International provisions of TIPRA. |
Mattson, Andrew M. |
|
Jul 1, 2006 |
1246 |
| How reduced rates for capital gains and qualified dividends affect the FTC. |
Sigler, John N. |
|
Jul 1, 2006 |
4032 |
| Availability of the foreign earned income exclusion, FTCs and combat pay exclusion for U.S. government contractors. |
Ballard, Christine |
|
Apr 1, 2006 |
980 |
| Check-the-box: not always the right answer for certain foreign corporations. |
Patelski, Robert |
|
Apr 1, 2006 |
959 |
| Back-to-back computer licensing arrangements narrowly carved out of the ambit of sec. 901(1)(1). |
Calianno, Joseph M. |
|
Feb 1, 2006 |
2052 |
| Notice 2005-64 completes the IRS's Section 965 trilogy. |
Stoffregen, Philip A. |
|
Sep 1, 2005 |
9738 |
| Marks & Spencer: EU claims for cross-border loss relief. |
Hare, Jonathan |
|
Jul 1, 2005 |
3184 |
| International provisions of the Jobs Creation Act. |
Biggart, Timothy B.; Harden, J. William; Livingstone, Jane R. |
|
May 1, 2005 |
1241 |
| Forms of overseas operations. |
Shum, Michael G. |
|
Apr 1, 2005 |
5524 |
| New regulations curtail abuse of foreign tax credit by partnerships. |
Mannino, Laura Lee; Lai, Richard |
|
Mar 22, 2005 |
3272 |
| Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas. |
Shum, Michael G. |
|
Mar 1, 2005 |
3983 |
| FTC baskets reduced to two. |
Zink, Bill |
|
Feb 1, 2005 |
800 |
| Interest expense allocation and apportionment options for FTC calculations. |
Zink, Bill |
|
Feb 1, 2005 |
766 |
| New repatriation dividend deduction. |
Gottschalk, Stefan |
|
Feb 1, 2005 |
1134 |
| Supercharged FTCs. |
Gottschalk, Stefan |
|
Feb 1, 2005 |
842 |
| Bringing it home: summary and analysis of the repatriation provision of the American Jobs Creation Act. |
Satkoski, Elizabeth |
|
Jan 1, 2005 |
12770 |
| Allocating foreign taxes: IRS rules that partnerships must allocate foreign taxes in proportion to foreign income. |
Graham, Michael |
|
Sep 1, 2004 |
769 |
| A guide to foreign corporation. |
Soltis, Sandra |
|
May 1, 2004 |
3656 |
| Potential opportunity to increase FTC use. |
Smith, Annette B. |
|
Jul 1, 2002 |
447 |
| Extraterritorial exclusion and the FTC. |
Packard, Pamela |
|
May 1, 2002 |
485 |
| CFC buyer's sec. 338 election deprives seller of FTCs. |
Zarzar, Robert |
|
Jul 1, 2001 |
1410 |
| Effect of NOL carryovers on FTC. |
Crocco, Peter |
|
Jul 1, 2000 |
537 |
| Sec. 904 - base difference vs. timing difference for foreign taxes. |
Fischl, Alan |
|
Jul 1, 2000 |
784 |
| FTC denied in Compaq due to lack of business purpose. |
O'Connor, Peg |
|
Jan 1, 2000 |
858 |
| International implications of check-the-box regulations. |
Barrett, James H.; Ewing, William P. |
|
May 1, 1998 |
5079 |
| IRS targets multinationals. |
Sheard, Tony J. |
|
May 1, 1998 |
2466 |
| Simplification proposal could ease complexities of AMT for some businesses. |
Lyon, Andrew B. |
|
Jul 1, 1997 |
948 |
| Entering foreign markets - one step at a time. |
Benson, David M. |
|
Oct 1, 1996 |
2876 |
| MNCs should start addressing sec. 404A issues. |
Windsor, Josh G. |
|
Jul 1, 1996 |
831 |
| Canadian company formed by U.S. S corporation will be considered a partnership. |
Zink, Bill |
|
Feb 1, 1996 |
642 |
| TEI endorses H.R. 1690, the International Tax Simplification and Reform Act of 1995. |
|
|
Sep 1, 1995 |
3029 |
| Determining foreign income tax credit. |
Weiss, Jeffrey |
Brief Article |
Aug 1, 1995 |
301 |
| U.K. taxation: a quiet revolution. |
Dent, Christopher H. |
|
Jul 1, 1995 |
1205 |
| Proposed section 902 regulations. |
|
|
Jul 1, 1995 |
4164 |
| Implementation issues for the Mexican nonresident income tax. |
Romine, Marshall |
|
Apr 1, 1995 |
1277 |
| Sec. 304: IRS reconsiders "foreign subsidiary stock transfer" rulings. |
Andrews, Jim |
|
Jul 1, 1994 |
788 |
| Response of Canadian Department of Finance to questions posed at TEI liaison meeting on income tax issues. |
|
|
Jul 1, 1994 |
2029 |
| The latest round on FTCs and net loans. |
Alexander, John |
|
Jun 1, 1994 |
1327 |
| Unraveling the mysteries of Sec. 304 in international tax planning. |
Jacobsohn, R. Bruce |
|
Mar 1, 1994 |
5551 |
| Miscellaneous international legislative proposals. |
|
|
Jul 1, 1993 |
951 |
| Clinton's tax plan: royalty and R&E provisions for multinationals. |
|
|
May 1, 1993 |
493 |
| FTC denied if competent authority not used in transfer pricing cases. |
Reavey, Edwin |
|
Apr 1, 1993 |
1675 |
| U.S.-Dutch agreement impedes treaty shopping. |
|
|
Mar 1, 1993 |
451 |
| Competent authority and FTCs. |
Berk, Nancy L. |
|
Feb 1, 1993 |
974 |
| U.S.-Russia treaty. |
|
Brief Article |
Oct 1, 1992 |
439 |
| Final regulations: CFC netting rule. |
|
Brief Article |
Jul 1, 1992 |
421 |
| FTC for individuals: treatment of 3% phaseout of itemized deductions. |
Dagg, Trevor |
Brief Article |
Jul 1, 1992 |
400 |
| Allocating charitable contributions in computing FTC. |
Fox, Stephen C. |
Brief Article |
May 1, 1992 |
418 |
| U.S. taxation of U.K. dividends. |
Hornsby, Brian |
Brief Article |
Apr 1, 1992 |
375 |
| Tax effects of the repeal of sanctions against South Africa. |
Watson, F. Douglas |
|
Nov 1, 1991 |
223 |
| Translation date for indirect foreign income taxes. |
Bernard, Michael J. |
|
Sep 1, 1990 |
586 |
| Comments on miscellaneous revenue issues considered at February 21-22, 1990, hearings, March 9, 1990. |
Burk, William M. |
|
Mar 1, 1990 |
2425 |
