The foreign tax credit (“FTC”) generally eliminates double taxation on foreign earnings that are repatriated and is intended to enhance the global competitiveness of U.S. companies. With careful planning, U.S. companies can maximize their use of FTCs and lower tax expense. We offer a wide array of FTC strategies and solutions designed to maximize the use of FTCs including:
- FMV and alternative tax book value for interest expense apportionment;
- Expense apportionment (861-8);
- Headquarters expense apportionment;
- Foreign source income maximization;
- Foreign title passage;
- OFL studies; and
- E&P studies.
Our professionals assist clients in using these and other planning solutions to best meet their tax needs.