US inbound update: Guidance on abusive foreign tax credit structures
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
To access our market-driven intelligence please request a trial here.
Read this article – and more – for a 30 day period.