901 Foreign Tax Credits

August 30, 2022

16 New Charts Published

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Posted on August 30, 2022 in 1293, 1295 QEFs, 1361 S Corporations, 367(d), 368 Corporate Reorgs, 861 Source of Income, 901 Foreign Tax Credits, Authority - Revenue Rulings, Charts - Situational Charts |

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March 18, 2022

Famous Tax Quotes - Congress Did Not Want To Deal With Citizens As If They Were Still In The Nursery

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Posted on March 18, 2022 in 901 Foreign Tax Credits, Other - Famous Tax Quotes |

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December 15, 2021

Five New IRS Practice Units

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Posted on December 15, 2021 in 453 Installment Sales, 59A BEAT, 701 Partnerships, 894 Treaties, 901 Foreign Tax Credits |

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September 02, 2021

New IRS Practice Unit - FTC (Business) General Principles

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Posted on September 02, 2021 in 901 Foreign Tax Credits, Other - IRS Practice Units |

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July 09, 2021

3 New IRS Practice Units

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Posted on July 09, 2021 in 250 GILTI & FDII Deductions, 861 Source of Income, 901 Foreign Tax Credits, Other - IRS Practice Units |

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April 12, 2021

New IRS Practice Units - FTC Carryback and Carryover & Liquidating Distributions of a Partner’s Interest in a Partnership

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Posted on April 12, 2021 in 701 Partnerships, 901 Foreign Tax Credits, Form 1116, Other - IRS Practice Units |

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July 18, 2020

New IRS Practice Units: Reasonable Cause and Good Faith & FTC Limitation

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Posted on July 18, 2020 in 901 Foreign Tax Credits, Other - IRS Practice Units |

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June 04, 2020

New IRS Practice Unit: Flow-Through Entities Effects on FTC

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Posted on June 04, 2020 in 901 Foreign Tax Credits, Other - IRS Practice Units |

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April 29, 2020

Three New IRS Practice Units

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Posted on April 29, 2020 in 453 Installment Sales, 901 Foreign Tax Credits, 986 Translation of Foreign Inc. Taxes, Other - IRS Practice Units |

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November 13, 2018

Updated IRS Practice Units by Topic Page

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Posted on November 13, 2018 in 367(b) Fgn to Fgn Corp, 367(d), 482 Cost Sharing Arrangements, 6038A 5472s, 6048 Foreign Trusts, 641-684 Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, 956 Investments in U.S. Property, 987 Branch Transactions, 988 Transactions, Other - IRS Practice Units |

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April 20, 2017

Updated - IRS Practice Units by Topic

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Posted on April 20, 2017 in 367(d), 6038A 5472s, 861 Source of Income, 901 Foreign Tax Credits, 988 Transactions, Other - IRS Practice Units |

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August 05, 2016

IRS International Practice Units By Category

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Posted on August 05, 2016 in 1441 U.S. Withholding Taxes, 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 6048 Foreign Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), Other - IRS Practice Units |

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March 31, 2016

New Videos - March 2016

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Posted on March 31, 2016 in 1441 U.S. Withholding Taxes, 368 Corporate Reorgs, 901 Foreign Tax Credits, Authority - Revenue Rulings, Charts - Situational Charts, Form W-8 BEN / BEN-E, Other - Videos |

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March 10, 2016

Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

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Posted on March 10, 2016 in 901 Foreign Tax Credits, 951 Subpart F Income, Authority - Revenue Rulings |

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September 07, 2015

Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period

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Posted on September 07, 2015 in 901 Foreign Tax Credits, Charts - Situational Charts |

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September 22, 2014

International PLRs of Note for the 38th week of 2014

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Posted on September 22, 2014 in 894 Treaties, 901 Foreign Tax Credits, Authority - PLRs / CCAs |

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July 28, 2014

Charts of Examples in Notice 2014-44

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Posted on July 28, 2014 in 901 Foreign Tax Credits, 901(m) Covered Asset Acquisitions, Authority - Notices, Charts - Situational Charts |

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December 06, 2013

International PLRs for the 49th week of 2013

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Posted on December 06, 2013 in 1291 PFICs, 482 Transfer Pricing, 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Form 8621 |

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November 09, 2013

Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes

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Posted on November 09, 2013 in 901 Foreign Tax Credits, Authority - PLRs / CCAs, Charts - Situational Charts |

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September 06, 2013

International PLRs for the 36th week of 2013

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Posted on September 06, 2013 in 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 |

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September 05, 2013

International PLRs of the 30th week of 2013

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Posted on September 05, 2013 in 1291 PFICs, 355 Spin-Offs, 7701-3 Check-the-Box Elections, 901 Foreign Tax Credits, Authority - PLRs / CCAs, Country - Canada, Form 8621, Form 8832 |

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August 31, 2013

Famous Tax Quotes - Double Taxation Cannot Always Be Avoided

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Posted on August 31, 2013 in 901 Foreign Tax Credits, Other - Famous Tax Quotes |

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August 25, 2013

International PLRs of the 21st week of 2013

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Posted on August 25, 2013 in 1291 PFICs, 351 Exchanges, 7701-3 Check-the-Box Elections, 901 Foreign Tax Credits, Authority - PLRs / CCAs, Form 8832 |

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International PLRs of the 20th week of 2013

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Posted on August 25, 2013 in 901 Foreign Tax Credits, Authority - PLRs / CCAs |

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February 05, 2012

Same Boat But Another Ocean

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Posted on February 05, 2012 in 901 Foreign Tax Credits, Other - Famous Tax Quotes |

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