Managing Foreign Tax Credits

Go to the IRS Website, located at http://www.irs.gov, and research the latest IRS “Publication 514” Foreign Tax Credit for Individuals. Based on your research, analyze at least two (2) requirements of a foreign tax levy to qualify for the foreign tax credit. Next, predict two (2) potential impacts of the foreign tax credit on dual capacity taxpayers. Imagine you are a tax advisor assisting a client with international tax planning, and the client has excess foreign tax credits. Propose a scenario to reduce your client’s tax liability by changing U.S. Source income into foreign source income in a way that will not generate any additional foreign tax. Provide specific examples of how your client can use tax laws to reduce source income and identify the applicable tax laws that support your recommendation.

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