Competent authority and FTCs. (foreign tax credits): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1993. The length of the article is 1001 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Taxes paid in a foreign country and claimed by a parent company as a deemed paid foreign tax credit on US taxes may result in the IRS reallocating income under IRC 482, according to revenue ruling 92-75. In the case in question, a US company failed to seek assistance from the Competent Authority or make an effort to seek an available refund of taxes paid in a foreign country by a subsidiary there.

Citation Details
Title: Competent authority and FTCs. (foreign tax credits)
Author: Nancy L. Berk
Publication:The Tax Adviser (Magazine/Journal)
Date: February 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n2 Page: 92(2)

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