The Final FTC Regs: Credibility for Creditability?

Cross-border Tax Talks

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Washington National Tax Services International Tax Leader Michael DiFronzo, former Deputy Associate Chief Tax Counsel International at the IRS. They discuss some of the practicalities of the creditability rules in the Final FTC regulations (see February 2022 CBTT episode with Wade Sutton for an overview of the regulations), particularly cost recovery, attribution requirements, an unintended incentive to offshore IP, and foreign jurisdiction considerations.