In Notice 2004-19, the Treasury Department and the IRS abandoned proposals announced in Notice 98-5 (1998-1 C.B. 334), to require foreign tax credit planning structures to satisfy a broadly worded economic-profit test and, instead, announced various specific steps to combat abusive foreign tax credit planning
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year