KPMG reports that the U.S. Tax Court that U.S. shareholder of CFC must use same method that CFC used to apportion interest expense for purposes of determining foreign tax credit in AptarGroup, Inc. v. Commissioner, 158 T.C. No. 4 (March 16, 2022). It’s summary begins as follows:
The U.S. Tax Court today issued an opinion concluding that the taxpayer must use the same method to characterize its controlled foreign corporation (CFC) stock for purposes of computing its foreign tax credit under section 904 as the method used by the CFC for interest expense apportionment.
The case is: AptarGroup, Inc. v. Commissioner, 158 T.C. No. 4 (March 16, 2022). Read the Tax Court’s opinion [PDF 150 KB] (nine pages)
Posted by Anthony Tran, Associate Editor, Wealth Strategies Journal