On March 1, 2017, the Internal Revenue Service (IRS) released a new International Practice Unit (IPU) summarizing foreign and domestic loss impacts on foreign tax credits (FTC). The IPU provides a summary of the law regarding worldwide taxation and FTC limitations, followed by explanations and analysis for IRS agents examining FTC issues. As we have noted previously, this high-level guidance to field examiners signals the IRS’s continued focus on international tax issues.
IRS Releases IPU Summarizing Foreign and Domestic Loss Impacts on FTCs
By McDermott Will & Emery on March 2, 2017
Posted In IRS Guidance, Uncategorized