TITLE

Foreign Tax Credits

AUTHOR(S)
Riedy, James A.
PUB. DATE
September 2010
SOURCE
International Tax Journal;Sep2010, Vol. 36 Issue 5, p11
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article focuses on the consequences of foreign tax credit (FTC) in the U.S. in cases where tax attributes of foreign target companies are retained. It discusses the foreign tax credit for the foreign income tax paid in connection with a covered asset acquisition under the New Code Sec. 901(m). It also discusses the application of the 1986 Pre-Tax Reform Act (TRA) FTC rules, the creditability of the income tax paid by the foreign target, and the application of the high-tax exception.
ACCESSION #
53697822

 

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