In another set of final regulations (T.D. 9922, released 29 September 2020), the United States (US) Treasury Department provided guidance for determining the foreign tax credit allowed under Internal Revenue Code1 Section 901. The final regulations (2020 final regulations) adopt proposed regulations that were issued on 2 December 2019 (2019 proposed regulations), with some modifications.2 In particular, the 2020 final regulations provide rules on the following:Foreign tax redeterminations under Section 905(c), including a new election to allow taxpayers to account for certain foreign tax redeterminations affecting tax years preceding the Tax Cuts and Jobs Act (TCJA) during their last tax year beginning before...