Hanna Oliveira Lauar
On December 28, 2021, the American Treasury Department released final regulations (TD 9959, Final Regulations) regarding foreign tax credit (FTC) to be offset in the USA. In a nutshell, the legislation under which the tax was paid abroad must be reasonably similar to US...
Our associate and tax manager of Azevedo Sette’ Tax team, Hanna Lauar participates of the text: “We don’t have any regulation on the master and local file, so all of that will be new. I don’t believe companies are yet prepared. They will need to evaluate what the actual...