Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations
On September 29, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations that provide guidance with respect to the calculation of foreign tax credits. The final regulations address a variety of computational issues, such as the allocation and apportionment of deductions under sections 861 through 865, the allocation of apportionment of foreign taxes, and the application of the foreign tax credit limitation to consolidated groups. The proposed regulations also address a variety of issues, such as the determination of foreign income taxes subject to the credit and deduction disallowance provision of section 245A(d), the impact of the repeal of section 902 on certain regulations issued under section 367(b), and the sourcing of inclusions under sections 951, 951A, and 1293.
Read More: Final Regulations
Read More: Proposed Regulations