Editor's note

The Internal Revenue Service has fired a shot across the bow of the HMS International Tax Planning with the issuance of Notice 98-5. The announcement declares war on tax planning in the foreign tax credit area. The Notice states the future regulations will disallow foreign tax credits in an arrangem...

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Bibliographic Details
Published in:International tax journal 1998-07, Vol.24 (3), p.III
Main Author: O'Connor, Walter F
Format: Article
Language:English
Subjects:
Editorials
Foreign tax credits
International
Profits
Tax planning
Tax regulations
Taxation
Treasuries
Withholding taxes
Online Access:Get full text
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Summary:The Internal Revenue Service has fired a shot across the bow of the HMS International Tax Planning with the issuance of Notice 98-5. The announcement declares war on tax planning in the foreign tax credit area. The Notice states the future regulations will disallow foreign tax credits in an arrangement from which the reasonably expected economic profit is insubstantial compared to the value of the expected foreign tax credits. Examples that Notice 98-5 sets forth of abusive foreign tax credit arrangements are provided.
ISSN:0097-7314