Wealth & Risk Management Blog

William Byrnes (Texas A&M) tax & compliance articles

The Changing Landscape of the Foreign Tax Credit Regime

Posted by William Byrnes on October 1, 2010


The tax landscape is changing for the amount U.S. multinational corporations may claim through the foreign tax credit.  This change is the result of the Statutory Pay-As-You-Go Act of 2010 that requires any increased spending must be offset by a corresponding increase in revenue.  The foreign tax credit modifications narrowly escaped becoming the offsetting revenue raising provisions of the Unemployment Compensation Extension Act of 2010 that extended unemployment benefits.  However, the success was short-lived, as these modifications were added to Pub. L. No. 111-226, the Education, Jobs and Medicaid Assistance Act  of 2010. This legislation provides $10 billion of elementary and secondary education funding to protect teacher jobs from being cut.  Nearly $10 billion over ten years is expected to be raised by altering various rules that corporations leverage to calculate their foreign tax credits and foreign-source income, providing the necessary revenue offset for this law.

In the article, we will examine the concept behind foreign tax credits offered in the United States; the history of foreign tax credits in the United States; the changes to the foreign tax credits; and the public policy behind the bill and the potential effects upon multinational corporations.  To download the free article, please link to LexisNexis here at Tax Law Community

You may post any questions or comments below  – Prof. William Byrnes

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