Michael Wilder

McDermott Will & Emery

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Latest Posts › Foreign Tax Credits

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Proposed Regulations Provide New Rules for Allocating and Apportioning Foreign Income Taxes Relating to Disregarded Payments

On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more

12/23/2020 / Foreign Tax , Foreign Tax Credits , IRS , New Rules , Proposed Regulation , Recordkeeping Requirements , Tax Cuts and Jobs Act , U.S. Treasury

Government Revises Base Difference Rules in New Foreign Tax Credit Regulations

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9922) (the 2020 Final Regulations) and related proposed regulations (REG-101657-20) (the...more

11/3/2020 / CFC , Foreign Tax Credits , IRS , New Regulations , Proposed Regulation , U.S. Treasury

Carryback of 2018 Foreign Branch Taxes to 2017

The 2017 tax act added two new separate foreign tax credit limitation categories, or baskets. Under current law, there are now baskets for income attributable to a foreign branch (the foreign branch basket) and for amounts...more

7/10/2018 / Federal Taxes , Foreign Tax Credits , GILTI tax

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