Court Allows Direct Foreign Tax Credit for Tax Paid by Disregarded Entity

Date

2005

Authors

Harvey, Carol Kulish
Outenreath, Alyson
Tod, Jim

Journal Title

Journal ISSN

Volume Title

Publisher

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.

Description

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).