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U.S. IRS and Treasury Issue Final Regulations Providing Guidance on Qualified Improvement Property and Foreign Tax Credit

27 September 2021

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Approved Changes

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United States

The U.S. IRS and Treasury have issued final regulations, Guidance on the Treatment of Qualified Improvement Property Under Sections 250(b) and 951A(d) and Guidance Related to the Foreign Tax Credit (TD 9956), which were published in the Federal Register on 24 September 2021. --- SUMMARY: This document contains final regulations under sections 250 and 951A addressing the calculation of qualified business asset investment ("QBAI") for qualified improvement property ("QIP") under the alternative depreciation system ("ADS"). This document also contains final regulations with transition rules relating to the impact on loss accounts of net operating loss (NOL) carrybacks allowed by reason...