BTAX OnPoint: IRS Extends and Expands Foreign Tax Credit Relief

Flexibility provided to taxpayers applying for the foreign tax credit was extended by the IRS, under new rules and guidance issued in December. The notice (Notice 2023-80) also provides new rules related to capturing credits for new Pillar 2 minimum income taxes being enacted by other countries party to the agreement.

The IRS and Treasury Department issued new rules to help taxpayers working on foreign tax credit calculations, both for 2023 and going forward, continuing to add flexibility to foreign tax credit rules it issued in early 2022 (T.D. 9959).

Corporations and other taxpayers that claim ...