Overview
Tax Notes quoted Amanda Varma in a February 3, 2022 article titled "Tax Treaties May Offer Relief From More Troublesome FTC Regs." The article centers on the final US foreign tax credit (FTC) regulations (T.D. 9959), which revamped the conditions for making a tax creditable. Companies now must evaluate whether their once-creditable taxes are still eligible for FTCs.
Tax Notes summarized commentary from Varma who shared that "while the FTC regulations are clear that residence- and payer-based sourcing are insufficient [to make a tax creditable under the FTC regulations], there are several other sourcing possibilities — like place of registration — that practitioners have questions about."
The full article can be read at Tax Notes (subscription required).
