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Corrections to U.S. Final and Proposed Regulations on Foreign Tax Credit Guidance Published

18 May 2020

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Approved Changes

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United States

The U.S. IRS and Treasury have issued corrections to Final and Proposed regulations on the determination of foreign tax credits originally published in the Federal Register on 17 December 2019. The corrections were published in the Federal Register on 15 May 2020. As previously reported, Final Regulations TD 9882 provide foreign tax credit guidance related to the Tax Cuts and Jobs Act, overall foreign loss recapture, and foreign tax redeterminations. Proposed Regulations REG-105495-19 provide guidance related to the allocation and apportionment of deductions and foreign taxes, financial services income, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), and...