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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.

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Will Foreign Tax Credits Be ‘LOST’ at Sea?

The International Seabed Authority is in the process of preparing regulations specifying the payments to be required from foreign companies for deep-sea mining concessions. Some experts estimate that in the long term, mining concessions granted by the authority may produce trillions of dollars of minerals, so these regulations can eventually have a very large economic impact. For U.S. parent companies of foreign mining subsidiaries that engage in authority-licensed deep-sea mining, a crucial question is whether the IRS will allow them to claim an income tax credit for the amounts charged by the authority to those foreign subsidiaries. Alan S. Lederman of Gunster, Yoakley & Stewart writes that under existing U.S. tax law the IRS is unlikely to concede an income tax credit for the payments required by the authority.

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By Lederman, Alan S., posted on Monday January 5, 2015

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