Foreign Tax Credits

Riedy, James A.
September 2010
International Tax Journal;Sep2010, Vol. 36 Issue 5, p11
Academic Journal
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.


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