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Federal Trade Commission (FTC) Foreign Tax Credits

McDermott Will & Emery

Corporate taxpayers: Key One Big Beautiful Bill Act changes to international and domestic taxes

McDermott Will & Emery on

On July 4, 2025, US President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation introduces significant changes to both international and domestic business tax rules for US taxpayers. While...more

McDermott Will & Emery

New Attribution Requirement Denies Foreign Tax Credits For Certain Withholding Taxes (And Other Taxes)

McDermott Will & Emery on

On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more

Alston & Bird

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

Alston & Bird on

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

Fenwick & West LLP

U.S. Tax Legislation Alert: Wyden Bill Proposes…

Fenwick & West LLP on

Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more

Alston & Bird

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

Alston & Bird on

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes....more

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