Brazil Transfer Pricing Overhaul Poised to Ease U.S. Tax Worry

Brazil’s move to overhaul its transfer pricing system to align with global standards could also help address an issue that’s been worrying multinationals: whether final U.S. rules will allow foreign tax credits for taxes paid in Brazil.

The possibility of losing many of their foreign tax credits is “a major, major concern” for companies after Treasury issued final rules late last year with stricter standards for which foreign taxes qualify for a U.S. credit, said Brian Jenn, a partner at McDermott Will & Emery LLP in Chicago. “That’s not a small concern, this is a concern on a magnitude of ...