The US Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations (REG-134935-11) with guidance on issues related to the computation of the US foreign tax credit (FTC) limitation under section 904 of the US Internal Revenue Code (IRC). Specifically, the proposed regulations address: –   the coordination of the rules for determining high-taxed income under IRC section 904(d)(2)(F) with capital gains adjustments under IRC section 904(b) and the allocation and recapture of overall foreign losses (i.e. foreign losses that have previously offset US-source income, OFLs) and overall domestic losses (ODLs) under IRC section 904(f) and (g); and...