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What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement

Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application...more

The Other Green Book: Treasury Explains Administration’s Tax Proposals

With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more

Back to School: Recent Cases Offer Lessons in International Tax “Basics”

In Liv. Commissioner (T.C. Summ. 2016-49), the taxpayer, appearing pro se, claimed he was entitled to education credits under Section 25A. The Tax Court disagreed, finding that the taxpayer’s U.S. residency start date made...more

IRS Unveils New Competent Authority Procedures

In the recent Rev. Proc. 2015-40, the IRS describes updated competent authority procedures for taxpayers seeking certain U.S. treaty relief. The new procedures, effective for requests on or after October 30, 2015, supersede...more

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