TITLE

Foreign Tax Credits

AUTHOR(S)
Reidy, James A.
PUB. DATE
September 2006
SOURCE
Journal of Taxation of Global Transactions;Sep2006, Vol. 6 Issue 3, p19
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article discusses the proposed Internal Revenue Code Sec. 901 on foreign tax credits for technical taxpayer rule in the U.S. The proposed regulation would revise the technical taxpayer rule to match the foreign tax with the income on which foreign tax is imposed. The proposal focuses on three topics: foreign consolidated groups, reverse hybrid entities, and hybrid entities. The rule will be modified to match foreign tax income as determined under foreign law.
ACCESSION #
24876738

 

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