Court Allows Direct Foreign Tax Credit for Tax Paid by Disregarded Entity
Date
2005
Authors
Harvey, Carol Kulish
Outenreath, Alyson
Tod, Jim
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Abstract
A direct foreign tax credit was proper when a company organized under Luxembourg laws by a U.S. parent company made or accrued advanced corporate income tax payments to Luxembourg. The company’s members did not have joint or several liability for the company’s Luxembourg tax liabilities.
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Keywords
direct foreign tax credit, disregarded entity, tax law, joint and several liability, tax liability, Luxembourg, Section 901
Citation
Carol Kulish Harvey, Alyson Outenreath, & Jim Tod, Court Allows Direct Foreign Tax Credit for Tax Paid by Disregarded Entity, 7 No. 4 Bus. Entities 52 (2005).