Location, Location, Location and Foreign Tax Credits
Tax policy attorney Joshua Odintz co-authored an article analyzing recently proposed foreign tax credit regulations. Specifically, the authors examine a new nexus requirement, discussing how it will operate if finalized by the U.S. Department of the Treasury as well as looking at other elements of the 2020 Proposed Regulations. Their article also covers the history of the foreign tax credit statute, including the modifications made by the Tax Cuts and Jobs Act, and briefly outlines the already-existing nexus requirement at the state level.
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