Your client is a
U.S.-based company that owns a foreign subsidiary. Your client understands
that there are foreign tax credits of which they may be able to take
advantage. Based on the e-Activity, recommend a strategy to optimize the
use of foreign tax credits.
You are an IRS
auditor and are auditing the foreign tax credits taken by a taxpayer in
order to determine if there was any abuse of the foreign tax credits
taken. Suggest the most likely abuse of foreign tax credits and measures
that the IRS can take to minimize lost revenue resulting from abuse.