Legal Alert: Allocation, Apportionment and Attribution, oh my – Proposed Foreign Tax Credit Regulations Provide Critical Guidance
Posted on Dec 6, 2018 in Uncategorized
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take into account changes to the Internal Revenue Code made by the Tax Cuts and Jobs Act (TCJA). The Proposed Regulations were highly anticipated because their application will significantly impact the practical cost to taxpayers of many provisions of the TCJA, most notably the new Global Intangible Low-Taxed Income (GILTI) provisions.