EYUS: Proposed regulations would revamp creditability rules for foreign income taxes
|Tax Alerts, National/Federal Taxation, L ...|United States
Executive summary
The latest United States (US) proposed regulations (REG-101657-20) on foreign tax credits would fundamentally revamp the rules for determining the creditability of a foreign tax under Internal Revenue Code1 Section 901 by requiring a foreign tax to meet a jurisdictional-nexus requirement (which would generally deny a credit for certain extra-jurisdictional taxes). The regulat…
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