Foreign Tax Credit Did Not Apply Against Net Investment Income Tax

The foreign tax credit did not apply against the net investment income tax (NIIT). The structure of the Internal Revenue Code made the credit inapplicable to the NIIT, and tax treaties did not override that fact. Under Code, Foreign Tax Credit Did Not Apply to NIITThe...

Penalty Relief for Certain Pass-through Forms

Partnerships, S corporations, and U.S. persons with interests in foreign partnerships may rely on transition relief from penalties for tax years beginning in 2021 with respect to new Schedules K-2 and K-3. These schedules may be required for: Form 1065, U.S. Return of...

Marriage Was Valid for Estate Tax Purposes

An estate was allowed a marital deduction because the decedent’s marriage was valid in the country of celebration. The decedent, who was Jewish, obtained a religious divorce under rabbinical law in New York from his first wife after a New York court had declared his...