Treasury Eyes Foreign Tax Credit Rules, Others By Year End (2)

The Treasury Department is aiming to issue a flurry of long-awaited tax regulations by the end of the year, including regulations on foreign tax credits, a Treasury official said Thursday.

Treasury also expects to issue rules by year’s end on previously taxed earnings and profits; elections under the passive foreign investment company rules; foreign pension funds under Section 897(l); and repatriations of intellectual property under Section 367(d), said Jose Murillo, Treasury’s deputy assistant secretary for international tax affairs, speaking at a Practising Law Institute virtual conference.

A package of rules on partnership aggregation could be out ...