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U.S. IRS Provides Temporary Relief for Foreign Tax Credit under Sections 901 and 903

24 July 2023

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Approved Changes

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United States

The U.S. IRS has issued Notice 2023-55, Temporary Relief Under Sections 901 and 903 of the Internal Revenue Code. --- Part III - Administrative, Procedural, and Miscellaneous Temporary Relief Under Sections 901 and 903 of the Internal Revenue Code Notice 2023-55 SECTION 1. PURPOSE This notice announces temporary relief for taxpayers in determining whether a foreign tax is eligible for a foreign tax credit under §§ 901 and 903 of the Internal Revenue Code (Code). This temporary relief, as described in section 3 of this notice, applies with respect to § 1.901-2(a) and (b) (the definition of a foreign income...