Washington (Feb. 25, 2004) -- Two notices just issued by the Treasury Department and the Internal Revenue Service aim to cut down several foreign tax credit abuses.
Notice 2004-19 describes the administrative and regulatory approaches the Treasury and the IRS are using to address foreign tax credit transactions that create results inconsistent with the purpose of the foreign tax credit rules. Notice 2004-20 halts a specific transaction designed to generate credits for foreign taxes paid on gain that is not subject to tax in the United States. The claimed result of the transaction is a foreign tax credit but no corresponding income and U.S. tax for the U.S. taxpayer.
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