The Final Foreign Tax Credit Rules: Complaints and Confusion

Tax Notes Talk

Raymond Stahl of Ernst & Young discusses concerns about the final regulations for claiming foreign tax credits, particularly how they affect creditability, withholding, and treaty benefits.
For additional coverage, read these articles in Tax Notes:

• Yellen Nixes Foreign Tax Credit Reg Delay, Defends OECD Talks
• Treasury Offers More Details on FTC Royalty Withholding Carveout
• Valuation Allowances Soften FTC Regs' Blow for Some Taxpayers
• FTC Analysis Worries Persist in Regs, USCIB Warns U.S. Treasury
• Tax Treaties May Offer Relief From More Troublesome FTC Regs
• FTC Regs’ Attribution Requirement Raises Administrability Issues

In our “In the Pages” segment, Kathleen Wright, director of the state and local tax program in the School of Taxation at Golden Gate University, chats about her Tax Notes piece, “The States’ Response to Wynne Seven Years Later.”
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• Tax Notes: @TaxNotes

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Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart