Treasury to Answer Open Questions in Foreign Tax Credit Rules

Forthcoming foreign tax credit rules will address some open questions that Treasury didn’t delve into in a recent package of related international tax rules.

The final rules package will address how the rules apply to 2018 through 2020, and an exclusive apportionment provision, Jason Yen, an attorney-adviser at Treasury’s Office of Tax Policy, said Thursday at an International Fiscal Association webinar.

• Those issues also relate to recent final rules (T.D. 9901) for the foreign-derived intangible income deduction, although Treasury didn’t get into them, Yen said.
• “This is just a matter of the fact that some of ...