On 1 March 2017, the U.S. IRS published an international practice unit: Summary of Foreign and Domestic Loss Impacts on the Foreign Tax Credit. The practice unit provides a general overview as well as detailed explanations of the rules regarding loss allocation, recharacterization, and recapture for: Overall Foreign Loss (OFL); Separate Limitation Loss (SLL); and Overall Domestic Loss (ODL). International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international tax concepts as well as information about specific transaction types. They are not an official pronouncement of law...