Partner Greg Hartker was quoted in a Tax Notes article discussing how the One Big Beautiful Bill Act (OBBBA) adjusts foreign tax credit (FTC) limitation calculations by excluding research and experimentation (R&E) and interest expenses from allocations to net-controlled foreign corporation–tested income.
Greg explained that the OBBBA’s alignment of R&E and interest expense treatment helps prevent expense allocations from crowding out FTC eligibility, a change that was a priority for congressional lawmakers and benefits US multinational enterprises.
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