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Insurers Seek ‘Non-Duplication’ Change Over Foreign Tax Credits

June 21, 2022, 9:46 PM

The Treasury Department and the IRS should modify a “non-duplication requirement” to provide more certainty to companies about whether certain foreign taxes are eligible for the foreign tax credit, a group of insurance companies says.

The non-duplication requirement under Section 903-1 comes into play when a foreign country imposes multiple different income taxes, like a corporate income tax and a general income tax, and a tax such as a gross basis tax on insurance companies’ premiums is imposed in lieu of one of those taxes.

  • Under the foreign tax credit rules which Treasury issued last December, such a substitute tax ...