The US Treasury Department and Internal Revenue Service (IRS) have issued final, temporary and proposed to curb abuses caused by transactions that artificially generate foreign tax credits. The regulations were published in the Federal Register on 16 July 2008. The final regulations replace the proposed regulations published on this topic in March 2007. In November 2007, the IRS announced in Notice 2007-95 that the portion of the proposed regulations regarding domestically owned foreign groups would be separated from the originally proposed regulations and would have a delayed effective date. The final regulations have adopted the temporary regulations dealing with structured...