Witnesses Urge IRS, Treasury to Tweak Foreign Tax Credit Rules
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Witnesses Urge IRS, Treasury to Tweak Foreign Tax Credit Rules
Witnesses at a hearing told the IRS and the Treasury Department that there is still more that needs to be done with the much-debated foreign tax credit regulations. Cost recovery and foreign royalty withholding taxes need more changes beyond those made in November’s proposed regulations. Specifically, calls are being made to define the scope of a new proposed test indicating that recovery of “substantially all” of certain costs is sufficient to qualify for the credit and for more clarity in the attribution requirement for royalties.
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