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Foreign Jurisdictions International Tax Issues

Freeman Law

The Foreign Tax Credit

Freeman Law on

U.S. taxpayers are generally taxed on their worldwide income. But what happens when that income is also taxed by another country? The Internal Revenue Code’s primary mechanism to alleviate this double taxation of income is...more

Freeman Law

Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit.

Freeman Law on

As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the U.S. tax system to reduce the impact of double taxation. In general terms, income that is derived from a foreign jurisdiction by a U.S....more

Miller Nash LLP

Today in Tax: Financial Contract Modification and Foreign Tax Credits

Miller Nash LLP on

Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued interbank offered rate (“IBOR”) will need to transition to an...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Going Global? Top 5 Labor and Employment Concerns for Multinational Businesses

In this episode, Diana Nehro, a shareholder in Ogletree Deakins’ International Practice Group, covers five of the most significant labor and employment concerns for multinational companies. Tune in for a discussion about...more

Bilzin Sumberg

How Windstream Ruling Will Affect Foreign Taxpayers

Bilzin Sumberg on

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and...more

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