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U.S. IRS and Treasury Issue Corrections to Final and Temporary Regulations on Foreign Tax Credits

06 October 2021

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Approved Changes

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United States

The U.S. IRS and Treasury have issued correcting amendments to the final and temporary regulations (TD 9922) that were published 12 November 2020, providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), consolidated groups, hybrid arrangements, and certain payments under section 951A. The correcting amendments were published in the Federal Register on 1 October 2021 and apply from 12 November 2020. --- SUMMARY: This document contains corrections to the final regulations (Treasury Decision 9922) that were published in the Federal Register on Thursday, November 12, 2020....