U.S. Tax Review: Puerto Rico FTC Notice, PTEP Regs and OECD BAPA Manual

By: Larissa B. Neumann , Julia Ushakova-Stein

In the latest installment of U.S. Tax Review, Fenwick tax partners Larissa Neumann and Julia Ushakova-Stein examine the creditability of Puerto Rican tax law, which changed following amendments to the U.S. foreign tax credit regulations; the withdrawal of the proposed regs on previously taxed earnings and profits; IRS guidance on advance payments and inversions and LB&I guidance on the section 965 transition tax; and the OECD’s bilateral advance pricing arrangement manual and its progress report on amount A.

Read the full Tax Notes article here.