junio 17 2024
A Bug or a Feature? Foreign Tax Credits for Offset Earnings
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Fuente: Tax Notes International
In this article, Pastore and Himmelstein examine a federal district court’s decision in FedEx and the recent controversy over US multinationals claiming the foreign tax credit for their foreign offset earnings, including the interaction between subpart F, the Tax Cuts and Jobs Act, and the FTC regime.
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