Foreign Tax Credit Planning in Washington DC
Representing Miami, Dallas, Orlando & Clients Worldwide
U.S. taxpayers concerned about avoiding double taxation and seeking to
minimize their worldwide tax liability must be prepared to navigate a
labyrinth of foreign tax credit rules in the Internal Revenue Code. The
old challenges remain: determining which foreign levies qualify for the
U.S. tax credit, which person is entitled to the credit, and the mechanics
of calculating and applying the credit.
Nowadays, however, taxpayers must also contend with IRS demands for substantiation
and payment above and beyond what has been required historically. This
makes it even more important to have tax counsel who knows both the written
rules and IRS enforcement practice.
Why work with Castro & Co.?
Castro & Co.’s International Tax Team has a wealth of knowledge
and experience dealing with foreign tax credit qualification and substantiation
issues. We have helped many taxpayers, and can help you, to structure
operations to make the most of the foreign tax credit rules on a prospective
basis, or to defend your entitlement to foreign tax credits previously claimed.
We have advised taxpayers on utilizing the title passage rule to permit
the full utilization of excess foreign tax credits and foreign E&P
planning to increase the amount of indirect foreign tax credits associated
with dividend distributions.
To make sure you get the most out of the foreign tax credit rules,
Castro & Co. can:
- Evaluate which taxpayer, and which foreign levies, will qualify for the
U.S. tax credit.
- Guide you through the “basket” characterization and calculation rules.
- Devise appropriate strategies to maximize your credits and to access excess credits.
- Advise you of the type of substantiation issues likely to arise.
- Defend your entitlement to claimed foreign tax credits at all stages of
- Invoke Competent Authority assistance to support the creditability of a
foreign tax and your entitlement to the credit.
We have offices in Washington DC, Miami, Dallas, and Orlando, but we represent
clients all over the world. Do not hesitate to call
(888) 595-5088 for a free consultation!