Strategizing International Tax Best Practices – by Keith Brockman

US FTC for UK DPT?

EY’s Global Tax Alert provides a summary of the US congressional developments, including a review for US Foreign Tax Credit (FTC) applicability of the UK’s Diverted Profits Tax (DPT) which went into effect April 2015.

This review highlights a renewed focus on receiving a US FTC for income that may have been taxed in another (low-tax) jurisdiction and for which a country asserts a right to tax in its jurisdiction.  The answer is not yet clear, and this analysis also points the way forward for similar tax measures being legislated by various countries.

http://www.ey.com/Publication/vwLUAssets/Report_on_recent_US_international_tax_developments_-_30_October_2015/$FILE/2015G_CM5920_Report%20on%20recent%20US%20international%20tax%20developments%20-%2030%20October%202015.pdf

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