Foreign Loss (DCL) Certifications

The U.S. based investor in an overseas enterprise faces myriad complex U.S. Federal tax rules concerning losses. Even domestic (U.S.) losses give rise to complications in the determination of the international aspects of U.S. taxation. Detailed record keeping is a must in order to both comply with U.S. tax rules, and to properly claim available tax benefits. Adding to this complexity, one must keep abreast of foreign rules concerning losses and the capture of associated deferred tax assets.

Among the items to consider in planning and tax compliance activities associated with losses are:

  • • Same Country Group Relief Provisions under Foreign Law
  • • Worldwide Group Relief Possibilities
  • • U.S. and Foreign Dual Consolidated Loss Rules
  • • Sorting Income and Deductions by Type
  • • Sorting Income and Deductions by Source
  • • Carryforward and Carryback Provisions
  • • Elections Affecting the Use of Losses
  • • Associations of Foreign Taxes to Categories of Net Income or Loss
  • • Implications on Transfer Pricing
  • • Modifications to Tax Laws Brought About by Bilateral Tax Treaties
  • • Funding Loss Making Operations
One of the more demanding of the many distinct areas of international tax planning, working through the issues associated with losses requires experienced oversight and goal driven processing of information. NEOITG, LLC is equipped to support your organization through the application of existing and custom built tools wielded by the experienced tax professional.