Oct 23 2020 42 mins 11
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Mike Urse (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently released final and proposed foreign tax credit (FTC) regulations. Doug and Mike (who participated in our inaugural CBTT podcast over two years ago) go deep on interest, stewardship, and research and development (R&D) expense apportionment under the final FTC regulations; the importance in modeling potential retroactivity of the R&D regulations; the intricacies in allocating and apportioning foreign taxes; foreign tax redeterminations under Section 905(c); the 'disregarded payment rule' under the proposed regulations; how to determine if a tax is 'creditable' and the new concept of 'jurisdictional nexus' in the proposed regulations; the revocation of the 'contested tax doctrine,' and additional proposed changes to the research and expenditure (R&E) allocation rules. Mike leaves listeners with a nice summary of the highlights and key takeaways from these regulations.
