Foreign Tax Internal Revenue Service

News & Analysis as of

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

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

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

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...

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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