Ways & Means Aide Addresses Allocation of Stewardship Expenses

Stewardship expenses are likely not “directly allocable” to a certain kind of foreign-earned income, a House Ways and Means Committee attorney said Friday.

In the easier fact patterns that come to mind, stewardship expenses are “probably not directly allocable” to net CFC tested income, or NCTI, Larry Pounders, tax counsel for the tax-writing panel, said. The result would be positive for companies concerned about the amount of foreign tax credits they can take.

He said he was speaking in his personal capacity at a virtual conference hosted by the International Fiscal Association. His remarks sought to shed some light on ...