US inbound update: Guidance on abusive foreign tax credit structures

May 22 2004

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

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

News Direct Tax

more across site & shared bottom lb ros

More from across our site

Direct Tax

Global tax equity: confronting base erosion in the digital economy

Countries which care about fair taxation of tech multinationals and equitable global distribution of wealth should back the UN’s tax framework, writes economist Abdelmalek Riad

Abdelmalek Riad, May 09 2025

Direct Tax

This week in tax: IRS has lost 11% of its workforce, report finds

The cuts disproportionately affected staff in certain positions, the report also found; in other news, MHA announced the €24m acquisition of Baker Tilly South East Europe

Sam Sholli, May 09 2025

Transfer Pricing

India sets APA resolution targets in 2025/26 action plan

The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India

Sam Sholli, May 08 2025

Direct Tax

Part of Eton College viewed from playing fields

This month in indirect tax: UK denies private school VAT breaches human rights law

Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films

Sam Sholli, May 07 2025

Direct Tax

Jaime Carey, president of the International Bar Association

IBA president: OECD’s two-pillar solution is ‘crucial’

Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency

Noemi Distefano, May 06 2025

Direct Tax

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

PwC to lay off ‘about 1,500 employees’ in US: report

Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said

Sam Sholli, May 06 2025

Direct Tax

WTS aims to capture PwC’s former francophone African footprint

WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview

Tom Baker, May 05 2025

Direct Tax

This week in tax: EU mulls pillar two revisions to placate US

The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign

Tom Baker, May 02 2025

Transfer Pricing

Bilateral APAs have their moment

For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality

Ralph Cunningham, May 01 2025

Direct Tax

Baker McKenzie picks up former US Treasury deputy Scott Levine

Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution

Tom Baker, April 30 2025