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Foreign Tax Credits Controlled Foreign Corporations Tax Credits

WilmerHale

International Tax Provisions of the One Big Beautiful Bill Act (OBBBA)

WilmerHale on

On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking a significant overhaul of the international tax landscape. This legislation introduces several key changes aimed at refining...more

McDermott Will & Schulte

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

McDermott Will & Schulte

Proposed Foreign Tax Credit Regulations Provide New Rules for Allocation and Apportionment of Deductions and Creditable Foreign...

McDermott Will & Schulte on

The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more

Holland & Knight LLP

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

Holland & Knight LLP on

• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC). • A foreign corporation...more

McDermott Will & Schulte

Proposed Foreign Tax Credit Regulations Clarify Taxpayers’ Ability to Claim Deemed Paid Credits

McDermott Will & Schulte on

On November 28, 2018, the Internal Revenue Service (IRS) and the US Department of the Treasury released proposed regulations (REG-105600-18) that address the calculation of a corporate US shareholder’s deemed paid foreign tax...more

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