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International Tax Blog - New and Interesting International Tax Issues


International PLRs of Note for the 38th week of 2014

2014-09-22

Today the IRS published the following Chief Counsel Advice relating to international taxation.

CCA 201438020 - An individual who is present in the United States solely for the purpose of education, training, or obtaining special technical experience and who receives benefits under Article 20 (Students and Trainees) of the U.S.-China Income Tax Treaty (the “Treaty” or the “Chinese treaty”) may in certain circumstances, begin employment as a teacher, lecturer, or researcher in the United States and receive benefits under Article 19 (Teachers, Professors and Researchers) of the Treaty without leaving the United States (or without leaving the United States for a period of more than one year). 

CCA 201438027 - Excess foreign income taxes that accrued in a taxable year in which
a taxpayer had no foreign source general category taxable income may properly be carried back and utilized as a credit in the previous taxable year, in which the taxpayer had foreign source general category taxable income but paid no creditable foreign tax.

Tags: 894 Treaties, 901 Foreign Tax Credits, Authority - PLRs / CCAs