The dep.’s law (T.D. 9846) is meant to dam multinational firms from claiming credit for overseas taxes paid on positive overseas company profits that have been offset through losses. The rule of thumb is tied to the overseas provisions of the 2017 tax legislation.
However a Tennessee federal courtroom just lately dominated the law will have to be put aside as it contradicted the legislation as handed through Congress. …
Supply Via https://information.bloomberglaw.com/daily-tax-report-international/fedex-court-win-gives-boost-to-multinationals-fighting-tax-bills