Cross-Border Business Combinations

Jackman, Patrick; Tretiak, Philip
September 2010
International Tax Journal;Sep2010, Vol. 36 Issue 5, p5
Academic Journal
The article focuses on the enactment of new Code Sec. 901(m) by the U.S. Education Jobs and Medicaid Assistance Act of 2010 for dealing with the foreign tax credit (FTC) for foreign income tax in connection with a covered asset acquisition. It discusses the transactions under the covered asset acquisition, the history of Code Sec. 338, the foreign tax credit that provides relief from double taxation, and the implications of Code Sec. 901(m) for U.S. buyers who want to acquire a foreign target.


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