Category: 901 Foreign Tax Credits

1. Chart of Example in Notice 2025-77

   December 20, 2025
2. Effective Tax Rate Calculations for Check the Box Analysis

   December 17, 2025
3. Notes on the OBBB

   July 27, 2025
4. Elections Related to Foreign Taxes

   May 16, 2025
5. 2 New IRS Practice Units

   May 2, 2025
6. 6 New IRS Practice Units

   April 17, 2025
7. 2 New IRS Practice Units

   April 4, 2025
8. 8 New IRS Practice Units

   March 25, 2025
9. 2024 IRS Tax Forum PowerPoints

   February 6, 2025
10. Three New FTC Practice Units

    January 30, 2025
11. Passive Income For Less Than 10% Limited Partner (Chart)

    October 13, 2024
12. New IRS Practice Unit - FTC - Categorization of Income and Taxes Into Proper Basket

    June 27, 2023
13. Musings on Structure Planning For Closely-Held Foreign Entities

    March 6, 2023
14. A Tangled Web of Definitions

    January 4, 2023
15. 16 New Charts Published

    August 30, 2022
16. Famous Tax Quotes - Congress Did Not Want To Deal With Citizens As If They Were Still In The Nursery

    March 18, 2022
17. Five New IRS Practice Units

    December 15, 2021
18. New IRS Practice Unit - FTC (Business) General Principles

    September 2, 2021
19. 3 New IRS Practice Units

    July 9, 2021
20. New IRS Practice Units - FTC Carryback and Carryover & Liquidating Distributions of a Partner"s Interest in a Partnership

    April 12, 2021
21. New IRS Practice Units: Reasonable Cause and Good Faith & FTC Limitation

    July 18, 2020
22. New IRS Practice Unit: Flow-Through Entities Effects on FTC

    June 4, 2020
23. Three New IRS Practice Units

    April 29, 2020
24. New Videos - March 2016

    March 31, 2016
25. Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

    March 10, 2016
26. Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period

    September 7, 2015
27. International PLRs of Note for the 38th week of 2014

    September 22, 2014
28. Charts of Examples in Notice 2014-44

    July 28, 2014
29. International PLRs for the 49th week of 2013

    December 6, 2013
30. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes

    November 9, 2013
31. International PLRs for the 36th week of 2013

    September 6, 2013
32. International PLRs of the 30th week of 2013

    September 5, 2013
33. Famous Tax Quotes - Double Taxation Cannot Always Be Avoided

    August 30, 2013
34. International PLRs of the 21st week of 2013

    August 25, 2013
35. International PLRs of the 20th week of 2013

    August 25, 2013
36. Famous Tax Quotes - Same Boat But Another Ocean

    February 5, 2012
37. U.K. Remittance Basis Charge ("RBC") is a Creditable Tax

    August 15, 2011
38. Double Taxation on Services

    July 26, 2011
39. New Section 956 Foreign Tax Credit Blending Rule

    August 13, 2010