id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-495	Brown, Karen B.	Neutral International Tax Rules Allocating Costs: Successful Formula for U.S. Research and Development	2022	21	.pdf	application/pdf	9985	570	50	However, the U.S. tax rules denied full credit for the foreign taxes to be applied against U.S. tax liability because foreign source taxable income, which determines the limitation on the foreign tax credit, was reduced by a portion of expenses from U.S. research activities. Congress had proposed research allocation rules in 1987 that were not enacted. 37.	cache/ftr-495.pdf	txt/ftr-495.txt