Skip to content

Brought to you by

Dentons logo

US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

open menu close menu

US Tax Disputes

  • Home
  • About us
  • State and Local (Subnational) Taxation

New Foreign Tax Credit Regulations Issued

By John Harrington and Marc Teitelbaum
February 15, 2012
  • Foreign Tax Credits
  • Offshore Reporting
  • Tax Conventions and Treaties
Share on Facebook Share on Twitter Share via email Share on LinkedIn

On February 14, 2012, the US Treasury Department (“IRS”) published in the Federal Register regulations dealing with two separate but related foreign tax credit issues. One set of regulations, which are proposed and temporary, provide guidance to taxpayers on how to interpret section 909 of the US Internal Revenue Code which denies a foreign tax credit for certain “foreign tax credit splitting events.” The other set of regulations, which are final, provide guidance on which person is considered to pay a foreign tax and is therefore eligible to claim a credit for the foreign tax paid.

Read more

Share on Facebook Share on Twitter Share via email Share on LinkedIn
Subscribe and stay updated
Receive our latest blog posts by email.
Stay in Touch
John Harrington

About John Harrington

John Harrington is the co-leader of Dentons' US Tax practice, which was recognized by The Legal 500 in 2020 for outstanding work in international and non-contentious tax. Recognized by Chambers Global as a Notable Practitioner, he advises clients on inbound and outbound transactional and compliance issues; international tax legislative, regulatory and treaty matters; and a variety of domestic tax issues.

All posts Full bio

Marc Teitelbaum

About Marc Teitelbaum

Marc Teitelbaum is the former chair of Dentons' Tax practice, which was recognized by The Legal 500 in 2020 for outstanding work in international and non-contentious tax. Marc has been involved in advising public companies, underwriters and investment funds principally in the following areas: acquisition and disposition of domestic and foreign corporations whether taxable or tax-free transactions; the US tax consequences of foreign operations and foreign joint ventures, in particular, multinational manufacturing and sales operations; debt and equity financings; and investment strategies in partnership form, including tax- and accounting-advantaged structured domestic and cross-border financing arrangements.

All posts Full bio

RELATED POSTS

  • Tax Conventions and Treaties

Cross-border exchange of information procedures

By Marc Teitelbaum
  • FATCA
  • Offshore Reporting

US Department of the Treasury Releases Proposed Regulations Implementing FATCA

By John Harrington
  • Corporations
  • Offshore Reporting
  • Transfer Pricing

Changes Proposed to US Tax Reporting Rules for “Outbound” Transfers

By Marc Teitelbaum, John Harrington, and Rich Williams

About Dentons

Dentons is designed to be different. As the world’s largest law firm with 20,000 professionals in over 200 locations in more than 80 countries, we can help you grow, protect, operate and finance your business. Our polycentric and purpose-driven approach, together with our commitment to inclusion, diversity, equity and ESG, ensures we challenge the status quo to stay focused on what matters most to you. www.dentons.com

Dentons boilerplate image

Twitter

Categories

Additional resources

Visit our Global tax guide to doing business in... 2022.

global tax guide 2022
Dentons logo

© 2023 Dentons

  • Legal notices
  • Privacy policy
  • Terms of use
  • Cookies on this site