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International Tax Articles

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August 16, 2017

OECD Moves to Limit Treaty Shopping

The Organization for Economic Co-operation and Development (OECD) released the key document that forms the basis of the peer review of the base erosion and profit shifting (BEPS) minimum standard on preventing inappropriate treaty shopping.

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Categories: International Business Issues
Tags: Action 6, BEPS, Inclusive Framework, international tax, OECD, Organisation for Economic Co-operation and Development, treaty shopping,
August 2, 2017

Returned Tax Payments Were Refunds for Purposes of Foreign Tax Credit

The Tax Court ruled that certain payments received by a U.S. citizen working abroad from a foreign taxing authority were in fact refunds under the Internal Revenue Code.

Facts of the case

A U.S. citizen worked for the London office of Goldman Sachs and received employee compensation from which United Kingdom income tax was withheld. The taxpayer filed both U.S. and UK income tax returns for each year at issue. On a timely filed U.S. return for each year, she claimed a foreign tax credit in an amount equivalent to the UK tax withheld by her employer.

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Categories: International Business Issues
Tags: foreign tax credit, Internal Revenue Code, international tax, returned tax payments,

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