Andersen Managing Director Joe Calianno's comments were included in the recent Tax Notes article, Treasury Proposes Royalty Carveout and Cost Recovery Safe Harbor. Calianno said that in general, the proposed regulations effectively address some questions that practitioners have had since the final foreign tax credit regulations were issued. He added that the examples included in the proposed regulations provide taxpayer-favorable outcomes in situations that occur on a regular basis.

Joe Calianno is a Managing Director in the US National Tax practice in the Washington D.C. office. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring.