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Internal Revenue Code (IRC) Double Taxation Foreign Tax Credits

Fenwick & West LLP

Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles

Fenwick & West LLP on

Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more

Allen Barron, Inc.

A New Wave of U.S. Expatriate Income Tax Refund Applications?...

Allen Barron, Inc. on

Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...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

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