New Law Significantly Alters FTC Regime, Practitioners Say

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Changes to the foreign tax credit under newly signed legislation (H.R. 1586; P.L. 111-226) represent significant alterations to the cross-border tax regime and create a host of questions for taxpayers, Ernst & Young LLP practitioners say. “These provisions represent fundamental changes in some longstanding international tax rules,” Barbara Angus, a practitioner in E&Y's national tax and international tax services, says in moderating a webcast on the new law. She notes that since some of these proposals were in legislation to extend expiring tax provisions, Congress likely will have to find new revenue raisers for that bill when they return from recess.