IRS Says Levy for Some Outside U.K. Eligible for Credit

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IRS unveils guidance treating the United Kingdom's long-term non-domiciliary levy as a tax eligible for the U.S. foreign tax credit under Section 901. IRS says in Rev. Rul. 2011-19 that for purposes of the credit, the LTND levy, paid by certain U.K. residents who live outside the United Kingdom, includes the “remittance basis charge” of 30,000 pounds ($48,727) that these taxpayers must pay in some cases. IRS says in the guidance that the LTND levy has the predominant character of an income tax in the U.S. sense because it is likely to reach “net gain” in certain circumstances.

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