Section 905(c) of the Internal Revenue Code provides rules on how to account for changes to foreign taxes if the amount paid differs from what was accrued for foreign tax credit purposes.
In New FTC Rules and Accompanying Regulations, published in the latest issue of Tax Notes International, Brian Abbey, GTM’s Managing Director of International Tax Services, and Inés Blanco, a tax consultant with WTS Global in Ghent, Belgium, review recent changes to foreign tax credit rules and their effect on foreign tax redeterminations, especially when amended returns need to be filed. They also examine the impact of the OECD’s initiatives on base erosion and profit shifting and the digital economy.
