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October 2013 » The Creditability of Foreign Taxes
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Sharon Burnett, PhD, CPA, and Darlene Pulliam, PhD
Internal Revenue Code (IRC) section 901 was enacted to allow U.S. companies a credit for certain income-type taxes paid to foreign countries; however, determining which taxes meet the requirements of this section is not always straight-forward. In 1997, the British government charged a windfall tax on a group of companies, including two U.S. multinationals. The IRS, the Tax Court, the Third Circuit Court of Appeals, and the Fifth Circuit Court of Appeals all had opinions on whether the windfall tax was a creditable tax. In May 2013, the Supreme Court's ruling settled the disagreement over this foreign tax.
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