OrbitaxU.S. Tax Court Holds Taxpayer Must Compute Foreign Tax Credit Using Same Method CFC Used to Apportion Interest Expense
|Approved Changes|United States
The U.S. Tax Court issued an opinion on 16 March 2022 concerning the apportionment of interest expense with respect to stock in a controlled foreign corporation (CFC) for purposes of the computation of a foreign tax credit. The case is summarized in the opinion as follows:
The Petitioner - "P" (AptarGroup Inc.) owns stock in a CFC that apportioned interest expense under the modified gross inco…
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