U.S. Proposed Regulations on Guidance Related to the Foreign Tax Credit
The U.S. IRS and Treasury have issued a notice of proposed rulemaking for consultation on Guidance Related to the Foreign Tax Credit (REG-112096-22). This includes proposed regulations relating to the foreign tax credit, including regulations addressing the following issues: (1) the definition of a reattribution asset for purposes of allocating and apportioning foreign income taxes; (2) the ap…
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