Tag Archive for Foreign Tax Credits

Expat Guide To Foreign Tax Credit Carryover

As an expat, no matter where you live and work, your US and foreign income is subject to IRS taxes. The fact that the majority of countries around the world also require you to file and pay tax locally makes the matter even more complex. In order to avoid double taxation, the US allows you to take a Foreign Tax Credit based on the foreign taxes you pay to your resident country. The Foreign Tax Credit is subtracted directly from your US income tax. However, if you cannot claim the full credit amount, you are allowed a carryover. Carryovers do expire, though, so read on to find out how best to utilize this savings! Read more

Do Tax Treaties Protect Expats From Double Taxation?

American citizens and green card holders, including people who have the right to U.S. citizenship, are required to file a federal income tax return each year declaring their worldwide income, wherever in the world they live. They may also have to pay U.S. taxes.

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Court of Appeals Reverses Santander’s Foreign Tax Refund

Ron Marini

The First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits.

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SCOTUS Declined Review of CA Decision Denying Foreign Tax Credit For Taxes Settled > 10Yrs After Return Was Filed

Ronald Marini

The Supreme Court has declined to review a decision of the Court of Appeals for the Federal Circuit that denied, as time-barred, a corporation’s refund claim for disputed foreign tax credits (FTCs). The Federal Circuit concluded that the 10-year statute of limitation period in Code Sec. 6511(d)(3)(A) for filing such claims began with date for filing the return for the year in which the foreign taxes originated, and not for the year in which the amount of the Read more

Canada Is Checking Foreign Tax Credits

It is not uncommon for e-filed returns or paper filed returns that claim a credit for US tax for CRA to request verification.

US tax paid per Canadian withholding slips are not requested because the slips are issued  by a Canadian entity. They are looking to US tax claimed per US reporting slips such as W2s, 1099s, 1042s or from the US 1040/1040NR tax returns. US social security tax and medicare (ie., FICA) is creditable if it relates to US source wages or services performed in the US which is evident  on the W2.

Foreign tax credits claimed in respect of US computed from  the US tax return based on determination of what portion of the tax payable of the return relates to US source income that is creditable is usually supportable by submitting to CRA your schedules and copy of the federal (and state where applicable) return. Recently CRA has Read more

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