In The Credit Crunch, a previous episode of this podcast series, we explored the final foreign tax credit regulations, which were ostensibly designed to target novel extraterritorial foreign taxes. But, since their introduction in December of last year, taxpayers have awaken to the reality that these regulations could render noncreditable a much broader set of foreign taxes.
In this episode, we return to the foreign tax credit regulations to explore the foreign taxes that are most “at risk” under the regulations and highlight the relevant considerations for taxpayers as they assess the credibility of each foreign tax paid or accrued.
Our host Gary Scanlon interviews Seth Green and Danielle Rolfes from International Tax group of the KPMG Washington National Tax practice to get their practical observations from analyzing the tax laws of numerous jurisdictions across the globe in light of the new foreign tax credit regulations.
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