Treaty between United States and Mexico – IRS to evaluate whether Mexican impuesto empresarial a tasa única qualifies for US tax credit

The US Internal Revenue Service (IRS) has announced that it and the US Treasury Department are evaluating whether the newly adopted Mexican impuesto empresarial a tasa única (IETU) can qualify for a US tax credit under Art. 24(1) (Relief from Double Taxation) of the 1992 US-Mexico tax treaty.

The announcement was made in IRS Notice 2008-3. The notice states that the IRS and the Treasury Department believe that the provisions, design, and full operation of the I…