Daily Tax Report ®

Foreign Tax Credit Rules Published Officially (1)

Dec. 16, 2019, 2:33 PMUpdated: Dec. 16, 2019, 5:04 PM

The IRS officially published final rules and proposed rules relating to foreign tax credits.

The rules were released Dec. 2 and appeared in the Federal Register Dec. 16. The final rules, T.D. 9882, solidified foreign tax credit rules proposed in December 2018, rules on foreign losses proposed in June 2012, and part of rules proposed in November 2007 having to do with a “U.S. taxpayer’s obligation to notify the IRS of a foreign tax redetermination.”

The proposed rules, REG-105495-19, address allocation and apportionment of deductions and foreign taxes, financial services income, foreign tax redeterminations, foreign tax credit disallowance...

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