TITLE

Foreign Tax Credits

AUTHOR(S)
Riedy, James A.
PUB. DATE
May 2007
SOURCE
International Tax Journal;May/Jun2007, Vol. 33 Issue 3, p11
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article discusses several issues regarding the established rule that a payment made to a foreign government is not considered a payment of foreign income tax for U.S. purposes if the payment is voluntary. It is noted that the rule applies even if the payment is regarded as payment of tax under foreign law. A question is also raised on the treatment of a foreign income tax payment in a transaction where a person voluntarily places itself within the taxing jurisdiction of a foreign country.
ACCESSION #
24908796

 

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