The Treasury Department proposed modifying and relaxing foreign tax credit rules it issued in January 2022 (T.D. 9959).
The agency published the guidance (REG-112096-22) on Nov. 22. The January regulations added strict new requirements that caused taxpayers to question whether certain foreign income taxes remain creditable.
The proposed rules generally apply to foreign taxes paid or accrued in taxable years ending on or after Nov. 18, but can be relied on earlier under certain circumstances.
Download the BTAX OnPoint: 2022 Proposed Foreign Tax Credit Regulations
The attached OnPoint discusses the proposal’s:
- Clarifications to the application of the cost recovery requirement; ...
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