The IRS is giving companies more time to put new license agreements in place that they may need to help their foreign royalty withholding taxes stay eligible for the US foreign tax credit.
The extension, in a notice (Notice 2023-31) issued Monday, is intended to give taxpayers enough time to amend their existing license agreements or implement new ones in order to qualify for a “single-country exception” on royalty withholding taxes that was proposed in November, a Treasury official said.
Taxpayers will now have until 180 days after the final regulations adopting the single-country exception are issued to ...
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