News & Analysis as of

Foreign Tax Internal Revenue Service

MoFo Tax Talk: Volume 9, Issue 4

by Morrison & Foerster LLP on

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

by Goulston & Storrs PC on

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

by Morgan Lewis on

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

Federal Circuit Narrowly Interprets Limitations Period for Foreign Tax Credit Refund Claims

by McDermott Will & Emery on

In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more

Tax Policy Update

by McGuireWoods LLP on

NUMBER OF THE WEEK: 52 percent. The likelihood that tax reform will happen in 2017 or earlier, according to the tax experts that participated in the Tax Council (TTC) and Ernst & Young (EY) Tax Reform Business Barometer in...more

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

by K&L Gates LLP on

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

PPL Corp. v. Commissioner of Internal Revenue

Brief For Southeastern Legal Foundation, Chamber of Commerce of the United States of America, CATO Institute, et al, As Amici...

by Cato Institute on

PPL, an American energy company, bought one of many state-owned British utilities privatized in the 1980s. In 1997, PPL became subject to the U.K.’s new “windfall tax,” which was based in part on “profit-making value”— the...more

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