The U.S. IRS and Treasury have issued a notice of proposed rulemaking for consultation on Guidance Related to the Foreign Tax Credit (REG-112096-22). This includes proposed regulations relating to the foreign tax credit, including regulations addressing the following issues: (1) the definition of a reattribution asset for purposes of allocating and apportioning foreign income taxes; (2) the application of the cost recovery requirement; and (3) the application of the source-based attribution requirement to withholding taxes on certain royalty payments. In general, the proposed regulations are proposed to apply to taxable years ending on or after they are finalized and published...