Are you smarter than a circuit court judge? Understanding the foreign tax credit

Are you smarter than a circuit court judge? Understanding the foreign tax credit

Watch this video and you'll be amazed at how much you'll understand about one of the most complicated international tax issues. You'll see how "smarter minds" get confused themselves and punt the problem to someone else to solve. The case of Eshel v. Commissioner, decided August 5, 2016, by the DC Circuit Court of Appeals admittedly is not for the faint of heart. However, by the end of this video, you will understand the court's concluding statements below or your money back*: "The Totalization Agreement is an international executive agreement that must be interpreted in light of its text and the shared expectations of the contracting governments. Because the tax court committed legal error in its analysis of those question, we reverse the judgment of the tax court and remand for further proceedings consistent with this opinion." We could just claim this is a Reason #5497 why international taxation is so blisteringly mind-boggling complicated and leave it at that. But no. We go head first, risking our own lives** and confronting the demons that lurk behind convoluted international tax court decisions***. However, that would be the easy way out. A foreign tax credit is a credit you are able to apply to your tax bull to taxes actually paid in a foreign jurisdiction. However, not all taxes qualify. In order to qualify, the tax must be related to income. But not all income-related taxes qualify. Oh wait. Now it just got more confusing. Just watch the video. This will all totally make sense. Trust us.**** * No money back. ** Our lives not actually risked. *** No demons actually confronted. **** This one comes back clean. It is OK to trust us. http://ift.tt/1RfwK1f http://youtu.be/8pjykNCAYk8 IRS Medic