Foreign Tax Credit Planning

Representing Clients from Around the Globe

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 for 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 a tax counsel who knows both the written rules and IRS enforcement practice.

Reach out to Castro & Co. at (833) 227-8761 for high-quality legal counsel and sophisticated tax planning. We are ready to put our years of extensive experience to work for you.

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 proceedings.
  • Invoke Competent Authority assistance to support the credit-ability 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 (833) 227-8761 for a free consultation!

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  • New York

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