Executive summaryThe latest United States (US) proposed regulations (REG-101657-20) on foreign tax credits would fundamentally revamp the rules for determining the creditability of a foreign tax under Internal Revenue Code1 Section 901 by requiring a foreign tax to meet a jurisdictional-nexus requirement (which would generally deny a credit for certain extra-jurisdictional taxes). The regulations also provide guidance for allocating and apportioning foreign taxes paid or accrued with respect to certain transactions that are disregarded for US federal tax purposes and address various issues relevant for determining a taxpayer’s foreign tax credit limitation.2Additionally, the proposed regulations would:Expand the existing rules under Section 901...