Transition Tax Regs Seek to Clarify, Not Interpret, the Law - McDermott Will & Emery

Transition Tax Regs Seek to Clarify, Not Interpret, the Law

Overview


Timothy Shuman said that proposed regulations for the tax code’s new Section 965 addressed some key questions for the first time. The question of how foreign tax credits apply to withholding taxes imposed on previously taxed income brought back to the United States “may have been one of the largest unresolved issues out there,” he said.