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IRS Issue Notice on Application of Foreign Tax Credit Noncompulsory Payment Rules to Amended Tax Decrees between MNEs and Puerto Rico

20 September 2022

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Approved Changes

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United States-Puerto Rico

The U.S. IRS has issued Notice 2022-42 on the application of the noncompulsory payment rules in the foreign tax credit regulations to amended tax decrees between MNEs and the Puerto Rico tax authority. This concerns changes in relation to manufacturing incentives that were recently enacted as part of Law No. 52-2022, which was signed into law on 30 June 2022. As previously reported, this includes the introduction of a new option allowing companies operating under manufacturing tax incentives laws to elect for the application of an alternative 10.5% income tax instead of the 4% excise tax on foreign corporations manufacturing...