IRS Foreign Tax Credit Rule Due Soon; PTEP Rules Slip to 2023

A much-awaited proposed new rule addressing some of companies’ complaints about the Treasury Department’s foreign tax credit regulations should be issued very soon, in “weeks, not months,” an IRS official said Friday.

Another high-profile rule proposal, on previously taxed earnings and profits, won’t be out until the first half of 2023, said Peter Blessing, associate chief counsel (international) for the IRS, speaking at a conference of the American Bar Association’s tax section in Dallas. Treasury officials had previously indicated at least the first part of these so-called PTEP rules were expected by the end of 2022.

The foreign tax credit ...