U.S. IRS and Treasury Issue Final and Temporary Regulations and Proposed Regulations on Foreign Tax Credits
On 12 November 2020, final and temporary regulations (TD 9922) from the U.S. IRS and Treasury were published in the Federal Register to provide guidance regarding the allocation and apportionment of deductions and foreign taxes, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), consolidated groups, hybrid arrangements, and certain payments under section 951A. …
Continue Reading