Cross-border Tax Talks

New FTC Regs: Raise your creditability score

Jan 9, 2023

34:15

Highlights

AI Chapters

Episode notes

Cross Border Tax Talks Podcast

02:00

Withholding Taxes in Latin America

02:23

How Do Effective Dates Work for Withholding Taxes?

01:41

Introduction

2min

The 2021 Final Regulations - What Are They?

3min

Is the Cost Recovery Requirement in the Final RACS?

5min

Is Substantially All a New Tax Requirement?

2min

Is There Still a Square Peg in the Round Hole?

3min

The 2021 Final Regs for Withholding Taxes - Source Based Attribution

3min

Withholding Taxes in Latin America

2min

What Is a Single Country License?

3min

The Course of Last Resistance Is Single Country License

2min

10.

Is There a Need to Do a 482 Analysis on a Disregarded Payment?

2min

11.

Re-Attribution Asset Rule for Disregarded Payments

3min

12.

How Do Effective Dates Work for Withholding Taxes?

2min

13.

What Advice Do You Have for Taxpayers?

2min

14.

Cross Border Tax Talks Podcast

2min

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ninee Dewar, PwC International Tax Services Principal, to discuss the recently released 2022 proposed foreign tax credit (FTC) regulations. These regulations relax some of the stringent creditability requirements that were set forth in the 2021 final FTC regulations. Doug and Ninee dive into changes to the cost recovery requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes.