United States: Final FTC regulations cause double taxation — Burden(s) falls on taxpayers

In brief

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.

Read the Report

Final FTC Regulations Cause Double Taxation — Burden(s) Falls on Taxpayers


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