Proposed Foreign Tax Credit and Section 163(j) Regulations to be sent to OIRA
On October 18, 2018, Lafayette G. Harter III, the deputy assistant secretary for international tax affairs for the Department of Treasury, announced that the proposed regulations focusing on foreign tax credits under section 904 are likely to be sent to the Office of Information and Regulatory Affairs (OIRA) for review on October 19 or the following week. Harter also announced that proposed regulations focusing on section 163(j), which limits the deductibility of business interest, will also be sent to OIRA within days. Harter stated that the proposed foreign tax credit regulations provide guidance on issues such as expense allocation and other issues related to the interaction between foreign tax credits and the global intangible low-taxed income provision of section 951A, as well as transition rules that address excess FTC carryforwards.
Read More: FTC and Section 163(j) Proposed Regs Going to OIRA Within Days