The US Treasury Department and Internal Revenue Service (IRS) have issued proposed regulations identifying taxpayers eligible to claim US foreign tax credits. The regulations are issued under Sections 901 and 903 of the US Internal Revenue Code dealing with US credits for direct and indirect foreign taxes and for "in lieu" of foreign taxes. The new regulations propose to amplify Sec. 1.901-2(f) of the current regulations. This section provides that the person by whom a foreign tax is considered paid for purposes of Secs. 901 and 903, and the person thus eligible to claim the US foreign tax credit, is...