The U.S. IRS has released an international practice unit on Exhaustion of Administrative Remedies in relation to claims for a foreign tax credit. In general, for foreign tax to be creditable, it must be compulsory, meaning it is required under the taxing authority of a foreign government. Foreign taxes paid in excess of what is legally required under foreign law are considered noncompulsory, noncreditable payments. Foreign taxes are generally deemed compulsory if two factors are met: The amount was determined using a reasonable interpretation and application of the foreign tax law; and The taxpayer has exhausted all effective and practical...