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Foreign Tax Credit May Not Be Available for Gains Derived Outside the U.S.

Volume 4 No 5    /    Read Article

By Galia Antebi and Kenneth Lobo

Merely because a foreign country imposes an income tax and the tax is creditable does not mean that effective relief from double taxation is available. The U.S. retains the first right to tax income and gains that are domestic in character, and the income or gain on which the foreign tax is imposed must be categorized as foreign for relief to be provided. Kenneth Lobo and Galia Antebi focus on this issue and advise that advance planning will be required.    See more →