Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application...more
With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more
In Liv. Commissioner (T.C. Summ. 2016-49), the taxpayer, appearing pro se, claimed he was entitled to education credits under Section 25A. The Tax Court disagreed, finding that the taxpayer’s U.S. residency start date made...more
In the recent Rev. Proc. 2015-40, the IRS describes updated competent authority procedures for taxpayers seeking certain U.S. treaty relief. The new procedures, effective for requests on or after October 30, 2015, supersede...more