FTCs and the "two-state problem" recognizing contested governments for tax purposes by Benjamin M. Satterthwaite
By: Satterthwaite, Benjamin M
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Material type: 
ArticlePublisher: 2020Subject(s): EMPRESAS EXTRANJERAS | IMPUESTOS | ADMINISTRACION TRIBUTARIA | VENEZUELA
In:
Tax Notes International v. 98, n. 11, June 15, 2020, p. 1263-1271Summary: In this article, the author considers the creditability of foreign taxes incurred by a taxpayer in a geographic area claimed by two governments, only one of which is recognized by the United States. This situation is complicated further by an active tax treaty, which is currently the case in Venezuela.
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| Artículos | IEF | IEF | OP 138-Bis/2020/98/11-4 (Browse shelf) | Available | OP 138-Bis/2020/98/11-4 |
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| OP 138-Bis/2020/98/11-1 The need to close the FATCA loophole to preserve the integrity of U.S. tax enforcement efforts | OP 138-Bis/2020/98/11-2 Canadian Appeal Court rejects government's treaty-shopping arguments against Luxembourg holding company | OP 138-Bis/2020/98/11-3 Transfer pricing and COVID-19 | OP 138-Bis/2020/98/11-4 FTCs and the "two-state problem" | OP 138-Bis/2020/98/12 Tax Notes International | OP 138-Bis/2020/98/12-1 COVID-19 challenges for the arm's-length principle | OP 138-Bis/2020/98/12-2 A case for higher corporate tax rates |
Disponible también en formato electrónico.
Resumen.
In this article, the author considers the creditability of foreign taxes incurred by a taxpayer in a geographic area claimed by two governments, only one of which is recognized by the United States. This situation is complicated further by an active tax treaty, which is currently the case in Venezuela.
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