15 March 2023

Andersen Managing Director Joe Calianno's comments are included in the recent Tax Notes article, Treasury Seems Wary of Adding Services to FTC Royalty Carveout.The article includes comments by Joe as well as other participants made at the Federal Bar Association's 2023 Tax Conference in a session titled Current Developments in International Taxation. Joe, who chaired the panel, raised some concerns regarding the practical implications of certain aspects of the proposed regulations addressing the Foreign Tax Credit (FTC) royalty carveout.