IRS Notice: Foreign Tax Credit, Dual Consolidated Losses in Relation to GloBE Model Rules, Extension, Modification of Temporary Relief (IRC §901)

Treasury and the IRS intend to issue proposed regulations under I.R.C. §59(l), §78, §704, §901, §903, §951A, §954, §960, and §1503(d) to address the application of the foreign tax credit and related rules and the dual consolidated loss (DCL) rules to certain types of taxes described in the GloBE Model Rules, the IRS announced. This notice also extends and modifies the temporary relief described in Notice 2023-55 for determining whether a foreign tax is eligible for a foreign tax credit under §901 and §903. [Notice 2023-80, 2023-52 I.R.B. __ (Dec. 26, 2023)]

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