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Companies Unhappy With Foreign Tax Credit Rules, Mull Next Steps

Jan. 12, 2022, 9:28 PM

Businesses are unhappy with the U.S. Treasury Department’s effort to limit the kinds of foreign taxes they can apply toward their U.S. tax bills—and they’re scrambling to figure out how to respond.

The Treasury Department had promised to make its final rules on foreign tax credits more flexible, but companies say they are still too onerous. They’re contemplating lobbying Treasury further, or trying to get the department to make changes to help the tax-credit rules mesh better with the pending 137-nation OECD global tax agreement, tax advisers say.

Some companies may choose to challenge the regulations in court, attorneys ...