Rewriting the Foreign Tax Credit Limitation (Again)

Rewriting the Foreign Tax Credit Limitation (Again)

March 2022, The Tax Magazine

In this article, Rob and Michael re-familiarize the reader with the policy bases for the design of the Foreign Tax Credit limitation as it has evolved over the past hundred years, to review how the current proposals compare with previous versions of such a limitation, and to consider an alternative approach that could potentially simplify the provisions that Congress is considering.