TITLE

International Taxation

AUTHOR(S)
Rowe, Kevin; Wessells, Diana
PUB. DATE
June 2007
SOURCE
Corporate Business Taxation Monthly;Jun2007, Vol. 8 Issue 9, p9
SOURCE TYPE
Trade Publication
DOC. TYPE
Article
ABSTRACT
The article presents information related to the proposed regulation �1.901-2(e)(5) in the U.S. The proposed regulation states that a U.S. taxpayer cannot claim a foreign tax credit for foreign income tax that is paid voluntarily. To be creditable, a foreign tax must be a compulsory payment and its nature must be that of an income tax which is determined under U.S. principles. In addition, a payment is not considered compulsory if it exceeds the taxpayer's liability under foreign law.
ACCESSION #
25150598

 

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