Daily Tax Report ®

Treasury to Address Gap in Foreign Tax Credit Rules

Feb. 1, 2020, 3:54 PM

Treasury hopes to help companies factor payments made by disregarded entities into foreign tax credit calculations, an official said.

A disregarded entity has one owner and isn’t recognized as separate from its owner for tax purposes. Proposed rules (REG–105495–19) issued in December left questions on whether foreign tax credits could be applied in some situations.

  • The confusion centers on payments made to a disregarded entity that doesn’t meet the definition of a foreign branch, Layla J. Asali, vice chair of the tax department at Miller Chevalier Chartered said Saturday. The rules didn’t address that situation, she...
To read the full article log in. To learn more about a subscription click here.