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US Treasury provides welcome temporary relief from controversial foreign tax credit regulations

26 July 2023

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Tax Alerts, National/Federal Taxation

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United States

The notice allows taxpayers to claim foreign tax credits that otherwise may not have been available.The relief period is limited, ending with 2023 tax years. However, Treasury is considering changes to the foreign tax credit regulations and further relief.Taxpayers should evaluate the notice's impact on their pending (or already filed) tax returns, financial statements, and foreign tax credit profile.In a notice released on July 21, 2023 (Notice 2023-55; Notice), the United States (US) Treasury Department announced temporary relief for taxpayers seeking a foreign tax credit by deferring key components of Treas. Reg. Sections 1.901-2 and 1.903-1, which were issued on...