Overview
On July 17, 2023, Tax Notes quoted Amanda Pedvin Varma in their piece titled, "Reservations Leave Lasting Questions for Treaty Policy." The article, written prior to the foreign tax credit relief provided in Notice 2023-55, discusses the interaction of the foreign tax credit and the relief of double taxation in tax treaties. The Senate Foreign Relations Committee report on the Chile - US treaty discusses a declaration that, "further work is required to fully evaluate the policy of 'Relief From Double Taxation' articles in future tax conventions and their relationship to U.S. domestic tax laws."
Amanda Varma states that the declaration is “likely acknowledging the position that existing U.S. tax treaties continue to provide indirect tax credits after the TCJA, an issue that has additional significance after the new limitations on creditability imposed in the 2022 final foreign tax credit regulations."
