D. Pastore, Anthony
A bug or a feature? foreign tax credits for offset earnings / by Anthony D. Pastore, Jeremy D. Himmelstein .-- , 2024
Anthony D. Pastore is a partner and Jeremy D. Himmelstein is an associate with Mayer Brown. In this article, Pastore and Himmelstein examine a federal district court’s decision in FedEx and the recent controversy over U.S. multinationals claiming the foreign tax credit for their foreign offset earnings, including the interaction between subpart F, the Tax Cuts and Jobs Act, and the FTC regime.
IMPUESTOS
EMPRESAS MULTINACIONALES
BENEFICIOS
CREDITO
FISCALIDAD INTERNACIONAL
ESTADOS UNIDOS
D. Himmelstein, Jeremy
Tax Notes International 1048-3306 v. 114, n. 12, June 12 2024; p. 1753-1758
A bug or a feature? foreign tax credits for offset earnings / by Anthony D. Pastore, Jeremy D. Himmelstein .-- , 2024
Anthony D. Pastore is a partner and Jeremy D. Himmelstein is an associate with Mayer Brown. In this article, Pastore and Himmelstein examine a federal district court’s decision in FedEx and the recent controversy over U.S. multinationals claiming the foreign tax credit for their foreign offset earnings, including the interaction between subpart F, the Tax Cuts and Jobs Act, and the FTC regime.
IMPUESTOS
EMPRESAS MULTINACIONALES
BENEFICIOS
CREDITO
FISCALIDAD INTERNACIONAL
ESTADOS UNIDOS
D. Himmelstein, Jeremy
Tax Notes International 1048-3306 v. 114, n. 12, June 12 2024; p. 1753-1758