Summary
At issue is the whether the amounts allocated to goodwill and a covenant not to compete with this business sale constitute U.S. source income or foreign source income for the purpose of allowing a foreign tax credit carryback.
See Also
International Multifoods v. Commissioner
At issue is the whether the amounts allocated to goodwill and a covenant not to compete with this business sale constitute U.S. source income or foreign source income for the purpose of allowing a foreign tax credit carryback.