International
Asia Pacific
EMEA
North America
Latin America
In the midst of ongoing efforts aimed at historic global tax reform targeting the US technology and pharmaceutical industries, Treasury and the IRS published regulations last month that have the potential to create an additional double tax burden for U.S. multinationals across all industries. These foreign tax credit regulations indiscriminately limit the definition of a creditable foreign tax, resulting in, in many cases, double taxation on the same item of income.
While we question the validity of certain aspects of these regulations (especially where substantial changes were made to the proposed regulations without a proper notice and comment period), the regulations’ effective date means that taxpayers must immediately address the significant consequences of these regulations.
With the erratic pace of global and federal tax developments, we feel strongly that protecting US businesses is a shared responsibility. Our Tax Planning and Transactions practice group has been entrenched in internal conversations concerning these regulations, and attorneys across our U.S. offices prepared this series of articles to begin a conversation with you.
This three-part series was first published in the Tax Management International Journal.
Final FTC Regulations Cause Double Taxation — Burden(s) Falls on Taxpayers
Copyright © 2024 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.
Are you sure want to delete comment ?
Scan this QR Code to share this content
