As the year wound to a close, Treasury and IRS left us with a parting gift to unwrap and analyze. In this episode, we consider the impact of the final foreign tax credit regulations on the allocation and apportionment of foreign taxes, on the approach to refundable credits, and on the longstanding principles under which we typically analyze foreign levies to determine whether they are creditable in the United States. What do these regulations mean not only for digital services and other “novel” taxes, but also some long-standing taxes levied by foreign jurisdictions? Do they require a fundamental shift in the way we examine creditability?
Our host Gary Scanlon interviews Kevin Brogan and Seth Green from the KPMG international tax group to find out what’s in the package and what these new rules hold in store for U.S. multinationals.