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Receipt of proceeds from this transaction will trigger an estimated $650 million cash tax liability, approximately $600 million of which is associated with the income tax due on Apache's Overall Foreign Loss account balance.
corporation thus must consider the applicability of several recapture rules at the time of the incorporation, including the overall foreign loss (OFL) recapture rules of Sec.
These adjustments (reported on Schedule J, Separate Limitation Loss Allocations and Other Adjustments Necessary To Determine Numerators of Limitation Fractions, Yearend Recharacterization Balances, and Overall Foreign Loss Account Balances) affect the numerator of the limitation fraction used to compute the foreign tax credit.
Perez has 13 years of experience advising clients on inbound and outbound international taxation, including acquisition and disposition planning, initial structuring for new country investments, tax efficient financing structures, foreign tax credit planning including expense apportionment and overall foreign loss planning, earnings and profits computation, transfer pricing and repatriation strategies.
1373(b), an overall foreign loss generally must be recaptured.
Finally, these laws added an overall foreign loss recapture.
A company's future use of the FTCs may also be affected by the carryback as a result of the potential recapture of overall foreign loss accounts, separate limitation loss accounts, and overall domestic loss accounts resulting from the NOL utilization.
The bills include an Overall Domestic Loss recapture rule that mirrors the Overall Foreign Loss recapture rule of section 904(f).