Cash Basis Taxpayer Who Has Not Elected Accrual Option for Foreign Tax Credit Reports Later Assessment for Credit Purposes in Year Paid

How taxpayers should deal with changes in the determination of foreign taxes due for purposes of the foreign tax credit was discussed in Chief Counsel Email 201534013.  Specifically, the question arose regarding a taxpayer on the cash basis of accounting who has not elected to report the foreign tax credit on the accrual basis that faced an additional assessment of foreign tax related to a prior year.

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