Foreign Tax Credit

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.