The latest round on FTCs and net loans. (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 June 1, 1994. The length of the article is 1379 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: The US Court of Appeals for the Seventh Circuit ruled that Continental Illinois Corp. was not entitled to foreign tax credits on a net loan because of insufficient documentation but was not required to gross up the loan. The IRS had denied the foreign tax credit because the lender, Continental, could only provide a letter from the Brazilian borrower stating taxes had been paid. The Court disagreed with the IRS ruling that the lender's income on the loan should be increased by the amount of the foreign tax credit even though the credit had been disallowed.

Citation Details
Title: The latest round on FTCs and net loans. (foreign tax credits)
Author: Angela W.Y. Yu
Publication:The Tax Adviser (Magazine/Journal)
Date: June 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n6 Page: 351(3)

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