Executive summaryOn 4 January 2022, the United States (US) Treasury Department published its third set of final regulations (T.D. 9959, the Final Regulations) on foreign tax credits since the enactment of the Tax Cuts and Jobs Act (TCJA). The Final Regulations adopt proposed regulations that were published on 12 November 2020 (the Proposed Regulations), with some modifications. For an Alert discussing the Proposed Regulations, see EY Global Tax Alert, US: Proposed regulations would revamp creditability rules for foreign income taxes, dated 9 November 2020.  The Final Regulations fundamentally revamp the rules for determining the creditability of a foreign tax under...