Executive summaryOn 7 April 2022, United States (US) Senate Finance Committee Chairman Ron Wyden and Senate Finance Committee Member Rob Portman released a discussion draft of proposed legislation that would disallow foreign tax credits for taxes paid to Russia or Belarus, and would also disallow certain other US tax benefits (Proposal). In particular, the Proposal would amend Internal Revenue Code1 Section 901(j) to deny foreign tax credits for taxes paid or accrued to Russia or Belarus. The Proposal would also eliminate other US tax benefits for persons within the Proposal's scope, including tax treaty benefits, benefits under Section 892, the trading...